December 7, 2010

Attorney #37619

IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS, COUNTY DEPARTMENT DOMESTIC RELATIONS DIVISION IN RE THE MARRIAGE OF LAURA J. WALSH Petitioner, v. WILLIAM J. WALSH Respondent. ) ) ) ) ) ) ) ) )

Case # 02 D2 30912 Calendar 24

NOTICE OF MOTION TO:

William Walsh
2210 Woodlawn Park Avenue McHenry, Illinois 60051-3649 Via Certified and Regular U.S. Mail

William Walsh
830 W. Route 22 #B56 Lake Zurich, IL 60047 Via Regular U.S. Mail

On December 1,0 ,2010 at or as soon thereafter as COlUlSe1 may be heard, I shall appear before the Honorable Judge Reynolds or any Judge sitting in her stead, in courtroom 203 of the Second District Court, 5600 Old Orchard Road, in Skokie, Illinois, and present the Petitioner's Verified Petition for Rule to Show Cause, to Modify Child Support, for Temporary Restraining Order and Preliminary Injunction and for Other Relief, a copy of which is attached hereto, at which time and a pear if you so desire.

in :OCl..~m.,

CERTIFICATE OF SERVICE The undersigned, a non-attorney, states that the within notice and pleadings therein referred to were 0 personally delivered, 0 transmitted by facsimile to the number indicated above and/or placed in the U.S. Mail properly addressed, with first class postage prepaid, to the parties at the addresses set forth above on December 7, 2010 before the hour of 5:00 p.m.
[?:?J

COLADARCI

AND COLADARCl #37619. ATTORNEYS FOR PETITIONER 155 NORTH MICHIGAN AVENUE - SUITE 375 - OnCAGO, ILLINOIS 60601 -TEL.312-616-4272

'.

November 9, 2010

Attorney #37619

IN-THE CIRCUIT COURT OF COOK COUNTY ILLINOIS, COUNTY DEPARTMENT DOMESTIC RELATIONS DIVISION LAURA J. WALSH Petitionerr

v.

Case # 02 D2 30912

WILLIAM

J.

"Joer

WALSH

Respondent. VERIFIED PETITION FOR RULE TO SHOW CAUSE, TO MODIFY FOR TEMPORARY RESTRAINING ORDER and PRELIMINARY and FOR OTHER RELIEF .NOW COMES THE Petitioner attorney, pursuant Anne M. Coladarci
I

Laura Walshr(

"Laura") by and through her and COLADARCIr and Section 101

of the Law Firm of COLADARCI

to 750 ILCS S/505{a) (5) (b), 750 ILCS 5/501(2), Code of Civil procedure,

Of the Illinois

735 ILCS 5/11-101

et seq., and

prays that this court: I. Find the Respondent, William J. Walsh ("Joe") in contempt of this court for his wilful and contumacious failure and refusal to: A. Pay full child support from November 2005- March 2008 ipay any child support from March 2008- [Current date] 2010; B. pay medical and insurance expenses and costs for his children; c. pay educational expenses and costs for his children; and D. provide tax returns and other required financial documents for the years 2005, 2006,2007, 2008r 2009, and 2010; to Laurar pursuant to the Judgment for

All of which are due and owing Dissolution of. Marriage; II.

Restrainr impound, and attach all cash, credit car ds , line of credit, bank accounts, and any and all other financial accounts, and as set.s., in which the Respondent has an interest of any kind, including as a fiduciary, trusteer or custodial of any trusts set up for educational expenses. Or any other reason, further including those under his custody and control in his current "Joe Walsh for Congress campaign; until he provides a full accounting of the activity and use of said accounts; and Furtherr enter a judicial lien against all of Joers assets in the amount of the unpaid child
tt

-1-

support
III.

and other drivers

unpaid

costs for

and expenseSi his failure to pay child supporti

Suspend his

licence

IV.

Order Joe to provide a full accounting of all his assets, income, debts and liabilities, and expenditures, including the use of his persona,l, family or educational or other trust funds, or other custodial accounts! etc.! over which he has any fiduciary control or any other interest, including as a trustee! or cuat.od.ian , bus iness interests; and campaign funds i from the entry of the Judgment of Dissolution of Marriage· (when he first failed to pay in full the child support he already owed, to the present daYi Reset Joe Walsh's child support employment as Congressman from the obligation, 8th Districti based and on his new

V.

VI.

Order the Respondent to pay the attorneys fees and costs by the' Petitioner in the preparation and prosecution petition.

incurred of this

In support 1. matter

thereof

Laura

states

as follows: of the parties and of the subj ect

This Court has jurisdiction

herein.

2. of Marriage Illinois. incorporated reference

On March 29, 2004 the ("Judgment") A copy of said therein is A.

court

entered

a Judgment of Dissolution
1

between

Laura

and Joe Walsh in Cook County the Parenting and Agreement
("JPN/)

Judgment with attached

hereto

incorporated

herein

by

as Exhibit

3. residential

Pursuant

to

the

JPA,
1

the

Petitioner,

Laura

1

was

awarded

custody of the parties

two (2) youngest chf Ldr en , Meganborn born 9/20/1994
1

12/5/1990, presently 16.

age 20, and Patrick,

presently

age

-2-

UNPAID

COUNT I CHILD SUPPORT

(5 YEARS)

4. paragraphs

The

Petitioner

restates

and

realleges

the

allegations

in

1 through

3, above, as if each paragraph

were stated verbatim

in this Count I. A) CURRENT 5. CHILD SUPPORT ORDER modified child

Pursuant to the Judgment,
f

and the subsequently

support orders to guideline 750 ILCS 5/510, sources, consulting

Joe was to pay, as and for child support, an amount equal (28% of his net statutory in accordance with income pursuant 750 ILCS income to any 5/505 to and

child support

5/505).

In addition,

Joe was to pay received by

28% of all other him, including income. but

net statutory not limited

from all bonuses,

fees, or any other

6.

The

child

support

order

entered

on November

18,

2005

set

Joe's monthly child support at $2,134. to November hereto

Said obligation

was nunc pro tunc is attached

1, 2005. A copy of the November herein as Exhibit

18. 2005 Order B.

and incorporated

7. monthly

A subsequent child support

order

entered

December

22, 2005

confirmed

the

amount

as $2,134. A copy of the December herein as Exhibit C.

22, 2005

order is attached

hereto

and incorporated

8.

No petition

to modify,

abate

or terminate

this child support

order has ever been

filed, by either
-3-

Joe or Laura.

B) 9. sources

JOES'S FAILURE

TO PAY CHILD SUPPORT Joe had several
1I

At the time the order was entered, of income, including "Advantage

different to pay

Futures.

He was ordered from

$1,135.75 per month, by an Uniform Futuresi Laura.

Order of withholding, payments

Advantage to

and to make two additional

of $500 each per month

10. through

From

November

2005,

until

March

2008,

Joe paid

$1,135.75

the order of withholding

payment

to Laura.

11.

However,

during

that time period, $500 payments.

Joe failed to make

any of

the second or third monthly per month from November

As a result,

'Joe owes $1,000 in past due

2005 to March interest

2008,

or $28.,000.00

child support, plus

statutory

of 9% simple interest.

12. either monthly

From April

I, 2008 to December payment

I, 2010,

Joe failed

to make

the first monthly $500 payments

of $1,135.75,

or the second

and third per

of child

support,

in the amount

of $2,135.75

mont.h, for a total of of $68,288.00, interest.

plus statutory

interest of 9% simple

13. support

As a result

of Joe's

failure

to pay, he owes past plus statutory

due child interest

through December

I, 2010 of $97/344.00,

of $17,950.00,

for a total of $115,294.00. -4-

(ISBA Spreadsheet

calculation

of interest reference a. Total

and principal as Exhibit summary D) .

attached

hereto,

and incorporated

herein

by

Child Supp. Due:

132,416.50 (32,936.75) 99,479.75 17,957.50 due 117[437.25

Pmts towards Child Supp: Total Bal. of Unpaid Supp: Due:

Total Interest Total

Support and interest

C) JOE'S INCOME,
14.

ASSETS

AND LIABILITIES[ of the Judgment,

AND HIS ABILITY according to

TO PAY

Since

the. entry

Joel s public

statements other

and filings,

he has been employed, and earning

a saiary

and

forms of income and compensation.

15.

He was employed up until (See Uniform Order for

at

least
I

March 2008

at

Advantage attached
see also

Futures. hereto Exbibi t Form) and J,

Support

dated as

04/14/2005,

incorporated Form B,

herein

by reference

Exhibit Financial

E;

U.S. House of Representatives

Disclosure

16.

According to his

campaign literature, working, inter alia, of

and financial

disclosure small

form, he has been diligently business Congress herein
fl

as a consultant, various hereto "Joe

ownerr internet

and

advisor. pages

(A copy are Fi

Walsh for

website

attached

and incorporated J
I

by reference

as Group Exhibit

see also Exhibit

Form B U.S .
I

-5-

House of Representatives

Financial

Disclosure

Form) .

17. other

Further, he has received

at least $4'79,863.92 in political and distributing those

and

contributions

and is collecting

funds for Inc" and

his election campaign. FEC Form 3 3rd Quarter incorporated

(A copy of "Joe Walsh for Congress Committee, 2010 (internet accessed) as Group Exhibit is attached G) . hereto

herein by reference

18. his

Over the course $35,500,

of the 2010 campaign, given that he

Joe personally to make any

loaned child (Group

campaign

which,

failed

support. payments Exhibit
G) .

to Laura because

he "had no money" is surprising.

19. gave

Joe has paid

himself

back at least $i4,200 G). Again, he failed

for the loans he to make . any child

himself.

(Group Exhibit to Laura

support payments

from these ret~rned

loan proceeds

20.

According

to his

campaign Barron

filings, Blvd"

the most Grayslake,

current

address

for his committee

is 218 North

Illinois, (Group Illinois, is 510 Ash

Exhibit G) . He previously after his condominium

lived at 329 Locust Street, Winnetka, foreclosed. The other address

was

Street [ Winnetka,

Illinois.

21. was paying

According

to an interview

with Fox News on April 26, 2010, Joe of $3,300 per month, starting

rent on the Locust

Street house -6-

from

at

least

June

2009,

[when

he

lost

his 2,

Evanston 26, and

condo 27,

in 2010

foreclosure]. attached

(Fox News

website

stories,

April

hereto and incorporated

herein by reference

as Group Exhibit HJ .

22. (News

Apparently, quoting

Joe moved Joe,

from Winnetka News

to McHenry Online

in May 2010. 30, 2010,

story,

statehouse attached

July

www.statehousenewsonline.com reference as Exhibit I).

hereto

and incorporated

herein by

23. $40,000

In the April

26, 2010 Fox interview,

Joe reports

that he made

a year in 2009 and 2008.

(Group Exhibit H)

24. Government

In his

"United

states

House

of

Representatives

Ethics

in 28,

Act Financial

Disclosure

Statement,

Form B" dated April

2010, Joe provides, Walsh's United

under oath,

the following

information Ethics

on page 2: (Joe Act and as

States House

of Representatives Form B"

in Government 28, 2010
J

Financial

Disclosure attached

Statement, hereto K) and

dated

April herein

Instructions, Exhibit Income

incorporated

by reference

J and Exhibit

and Employment:
Employer Location chicago Type salary
2009 $11,732. 2010

i.

Advantage Futures united Republican Fund of Illinois

sa

$0.00

ii.

Winfield

salary

$0.00

$21,000.00

(Jan-April
2010)

-7-

iii. iv

Michigan Ventures

Ave.

Chicago Winnetka

Commission

$2,500.00 $8,3l1.00 $22,543.91

$0.00 $0.00 $2l,000.00

Joe Walsh, Self-employment

25. Joe made

According $21,000

to the

financial

disclosure

statement,

Exhibit income.

J,

in 2009, and $22,543.91

in 2010 in earned

26. following

The

Financial

Disclosure

Statement

(pages

3-4)

states

the

regarding

his assets

and unearned

income:

Assets Source

and Unearned

Income: Value
$15,00050,000 $1-1,000 $1-15,000 $0.00 $1-15,000 $0.00 $0-1,000 $l-15,000

Type of Income
interest interest interest Rent interest Economic dividends dividends interest

Amount/year
$l-200: $201-1000: $1-200: $1-200: $1-200: $1-200: $0: $5-15,000: $l-200: $1-200: $15-50,000: $15-50,000: $0: $1-2,500: $200-1000: $200-1000: 2010 2009 2010 2009 2010 2009 2010 2009 2010 2009 2010 2009 2010 2009 2010 2009

Northern Trust Bank (Chicago) Northern Trust Bank (Chicago) Charles 401 (k) Schwab

Condo (Evanston) SURS Pension Everburg Partners Group

The Miller Hon IND

27. make any

During this same time period, child support payments because -8-

Joe told Laura that he could not he had no income. Despite the

requirements provide

of the Judgmentr

and despite or other

Laurars request,

he refused to to back up

her with any tax returns

income information

his claim of poverty.

Failure 28.

to disclose

other

employment

and income of Laura

sources any compensation

Furtherr he has failed

to disclose

he may have received from the a) John and Kathleen Buck Family Foundation (Advisor), b) Administstaf£ Companies,
c)

Kingwood,

Texas

(Consulting

on

Fundraising Development) ; and Illinois

Fabretto
I

Children's Foundation,

Chicago,

(Fund-raising Services) Disclosure
,

or any retained educational Schedule IVr Schedule

funds (Form
J) .

B Financial

Liabilities 29. His Form Br Financial Disclosure Statement, Schedule III,

,

Statementr

VIr Exhibit

LIABILITIES, Disclosure

does not list his unpaid Statementr Schedule

child support. J) .

(Form B Financial

III, Exhibit

30.

ApparentlYr other

Joe

has

also which

failed

to pay

other

debts rand

failed

to disclose

income

is relevant

to the determination to Laura regarding the

of his income, and liabilities, same. (T) (gw)

and his statements

31.

The apparent

availability

of large sums of money has allowed

from either

his employment, a comfortable pay child

his family or his campaign lifestyler or any while

him to live quite to

at the same time, due to his failure share -9of educational costs

support

of his

or medical

\

expenses,

Laura and his children

were

denied

any of these advantages.

32.

Due to the repeated employment,

conflicts assets,

between his statements and expenses,

to Laura and his

about his income,

liability,

campaign finance government

filings,

and his public statements

regarding

his business and personal activities Joe provide an accounting, of his income, and the

and his finances, Laura demands that the total amount additional child

in order for her to determine sources
i

and

from

that

any

support

that may be duwe to her.

33. enforceable

Each

monthly

child

support

arrearage

amount

is a

separate

judgment,

and cannot be changed support payment

by the court, after 30 days became due.

have elapsed

since the child

34.

An award of 9% statutory

interest

on the individual

judgments

is mandatory.

35. incurred

Laura

has

a right

to

collect child

her

attorneys

fees

and

costs

in the collection

of unpaid

support.

36. and Joe

Laura has repeatedly has ignored her

demanded and

that· Joe pay the child support, refused to make the payments

requests

required. abate,

Further,

as pointed

out above,

Joe has never moved to modify, but has instead told Laura

or terminate

his support·obligation, to pay her. -10-

that he didn1t have enough

37. compelling

Joe's failure to pay was willful and cont.umac i.ous and without , cause or justification.

38.

LAURA

has incurred attorneys of this petition.

fees and costs in the preparation

and p~esentation

WHEREFORE, this Honorable and grant prayer

the Petitioner,

LAURA Walsh

respectfully

requests

that

Court: Order Joe Walsh to pay the child support arrearage; relief prayed for in the final comprehensive is incorporated herein by

her the further relief of this

for

petition,

which

reference.

FAILURE

COUNT II TO PROVIDE TAX RETURNS

(5 YEARS)

39. paragraphs

The

Petitioner

restates

and

realleges

the

allegations

in

1 through 38, above,

as if each paragraph

were stated verbatim

in this Count II. 40. Parenting The Judgment/JPA provides in paragraph 2.~ A of the Joint

Agreement:

A .. " Child Support will be adjusted to reflect increases in Husband's salary, and the Husband shall provide his W-2, 1099 S r and Federal and State tax returns in every year within 15 days of receipt or filing thereof.
I

41. and refused

As of the filing to provide

of this Petitionr of his W2's,

the Respondent

has failed

copies

1099's and Federal and State

-11-

tax

returns

for

any

year

or

partial

year

since

the

entry

of

this

Judgment,

2005, 2006, 2007,

2008, 2009, 2010.

42.

Pursuant

to the Judgment,

Joe is required

to provide

them to

her. Despite her demands, of the Judgment, information documentation Year 2005 2006 2007 2008 2009 2010

and the mandatory, and

self-executing

requirements minimal

Joe has refused,

since 2005. has provided

to her on his finances. are:

The missing

tax returns and back up

Missing Return Federal Federal Federal Federal Federal State State State State State"

And Missing Additional Documentation "Schedu les, Attachments, Schedules, Attachments, Schedules, Attachments, Schedules, Attachments, Schedules, Attachments, W-2s, 1099's, and Bac::k documentation Up W-2s, 1099's, and Back Up documentation W-2s, 1099's, and Back Up documentation W-2s, 1099's, and Back Up documentation W-2Si 1099's, and Back Up documentation

not due yet

W-2s, 1099's, and Back Up documentation

43.

Laura

has

demanded, that

and

the

Judgment

imposes

a mandatory, Schedules,

self-executing Attachments, her requests as pointed

obligation W-2s,

Joe provide

his Tax Returns,

1099's,

and Back Up documentation. any financial

Joe has ignored Further,

and refused

to provide

information.

out above,

Joe has never moved this

to modify,

abate, or terminate

his obligation

to provide

information.

44.

Joe's

failure

to provide

the documentation

required

by the

Judgment/JPA was willful

provided and

in paragraph

2.~ A of the Joint and -12 without

parenting

Agreement cause or

contumacious,

compelling

justification.

Joe's

failure

to pay child support, and to provide income

tax forms and information, is willful, and

and abide by the other terms of the Judgment, and with out compelling cause or

contumacious,

justification.

45.

LAURA has incurred

attorneys

fees and costs in the preparation

and presentation

of this petition.

WHEREFORE, this Honorable

the Petitioner, Court: Order his Joe

LAURA Walsh respectfully Walsh to immediately

requests with

that his

comply

obligation

to provide

tax returns, prayer

and grant h~r the relief prayed which

for in the final comprehensive is incorporated

for relief of this petition,

herein by reference.

COUNT III JOE'S FAILURE TO PAY CHILDREN'S MEDICAL, INSURANCE EDUCATIONAL, AND EXTRACURRICULAR EXPENSES

PREMIUMS,

46. paragraphs

The

Petitioner

restates
I

and

real leges

the

allegations

in

1 through/4i~/above

as if each paragraph were stated verbatim

in this Count III.

47. 2.2 of the

The Judgment/JPA Joint Parenting chi1dren's

provides Agreement expenses

in paragraph that

2.1 C, and paragraph are to equally insurance expenses,

the parties

share the parties'

for medical medical

and dental and dental

for the kids, uninsured

and extra-ordinary

-13 -

and extracurricular

and educational

expenses.

48.

The Judgment

states

that the parties medical expenses

are equally of Megan

responsible

for ordinary In addition,

and extraordinary Joe is required between plans to

and Patrick. (1/2) of for

reimburse

Laura for one-half

cost of difference medical insurance and dental

family provided

plan and individual through Laura's

plan premiums health and

dental

plans.

49. educational,

Laura

has

paid

100%

of

these

joint

bills

and Laura

expenses

for

extra-curricular

and medical

expensesi

has provided payment from

Joe with documentation Joe, but medical, Joe has

of each and every bill, and demanded to pay his share

refused

of the parties' expenses.

chf.Ldr-en+s

insurance,

extracurricular

and educational

50. a. b. c. d.
TOTAL DUE

The expenses Educational

Joe has failed to pay are summarized Expenses:

as follows: $1,981. 50 $1,920.50 $2,624.50

Extra-Curricular: Medical Health Expenses: and Dental Insurance Premiums:

$3,113.28 $91639.78

(Spreadsheet of Expenses by reference attached as Exhibit L)

are attached

hereto and incorporated said spreadsheet

herein is not

[For privacy but

reasons,

and filed herein,

is available

for review upon request] .

-14 -

51. terminate

As pointed out above, Joe has never moved to modify, his obligation,

abate, or

but has instead told Laura that he didn't have

enough to pay her.

52. compelling Judgment,

Joe's failure to pay was willful and contumacious, cause or justification. is willful, and abide by the other

and without terms of the

and contumacious.

53.

LAURA has incurred attorneys of this petition.

fees and costs in the preparation

and presentation

54. incurred

Laura has a right in the collection

to collect

her attorneys expenses.

fees and costs

of these

unpaid

WHEREFORE, this Honorable as set forth comprehensive

the petitioner, Court: Order

LAURA

Walsh

respectfully

requests

that

Joe Walsh her

to pay his share of the expenses, for in the final is incorporated

herein, prayer

and grant for relief

the relief prayed which

of this petition,

herein by reference.

PETITION

COUNT IV TO RESET JOE WALSH'S CHILD SUPPORT OBLIGATION, BASED ON HIS NEW EMPLOYMENT

55. paragraphs

The one

Petitioner through 54

restates above
I

and as if

realleges each

the

allegations were

in

paragraph.

stated

-15-

verbatim

in this Count IV.

56. substantial meaning

Since the Entry of the Judgment changes purview of Marriage in circumstances of Section

there have been material nature, within

and the and

of a continuing 510 of the

and

Illinois

Marriage

.Dissolution

Act

("IMDMA")

, 750 ILCS 5/510(a)

·57.

The changes

that have taken place from the
St.h

are that Joe is starting Congressional District,

a

new position,

as the Congressman

and

his income will increase has increased

to approximately and

$174,000 per year, his income way, necessitating an

in a substantial

significant

increase

in child support,

and further, in his true

said award should be retroactive income.

to the date of the increase

58. based

Laura seeks to have his child support obligation redetermined, in gross order, income subject to child supporti entered. and to

on an increase

have a new child support

and order

for witholding

WHEREFO~, the Petitioner,
this Honorable Grant cou:rt: determine prayed

LAURA

Walsh

respectfully

requests

that and for

Joe Walsh's

child support obligation, comprehensive prayer

her the relief

for in the· final is incorporated

relief of this petition,

which

herein by reference.

-16-

PETITION

TO SUSPEND

COUNT V JOE WALSHIIS DRIVERS

LICENSE

59. paragraphs verbatim

The one

Petitioner through 58

restates

and

realleges if each

the

allegations were

in

above , as

paragraph

stated

in this Count V.

60. delinquent

As

set

forth

he.re i.nabove, Joe of child support.

Walsh

is more

than

90

days

in the payment

61. Marriage

Section Act

505

(b) of the Illinois

Marriage

and Dissolution

of

("IMDMAIf) provides:

Failure of either parent to comply with an order to pay support shall be punishable as in other cases of contempt [as in other caaes of failure to comply under the "Illinois Marriage and Dissolution of Marriage Act", as now or hereafter amended.] In addition to other penalties provided by law the Court may, after finding the parent in contempt order that the parent ...in cases where the parent is 90 days or more .delinquent in payment of support or has been adjudicated in arrears in an amount equal to 90 days obligation or mor'e, that the parent's Illinois driving privileges be suspended until the court determines that the parent is in.compliance with the order of support. The court may also order that the parent be issued a family financial responsibility driving permit that would allow limited driving privileges for employment and medical purposes in accordance with Section 7 -702.1 of the Illinois Vehicle Code. The clerk of the circuit court shall certify the order suspending the driving privileges of the parent or granting the issuance of a family financial responsibility driving permit to the Secretary of State on forms prescribed by the Secretary. Upon receipt of the authenticated documents, the Secretary of State shall suspend the parent's driving privileges until further order of the court and shall, if ordered by the court subj ect to the provisions of Section 7-702.1 of the Illinois Vehicle Coder issue a family financial responsibility driving permit to the parent.
1

-17-

62.

This court must inform child support

the secretary

of state that Joe Walsh

has an unpaid

arrearage.~

63. secretary

Pursuant of state

to

625

ILCS Joe

5/7 -7022 Walsh
l

I

this

court

can

order

the

to suspend

s drivers

license

for unpaid

child support.

64.

Laura

seeks to have Joe's

driver1s

license

suspended,

until

such time as he is current

in his child

support and arrearages.

1

(625 ILCS 5/7-703)

Sec. 7-703. Courts to report non-payment of court ordered support. (a) The clerk of the circuit court, as provided in subsection (b) of Section 505 of the Illinois Marriage and Dissolution of Marriage Act or as provided in Section 15 of the Illinois Parentage Act of 1984, shall forward to the Secretary of state, on a form prescribed by the Secretary, an authenticated document certifying the court's order suspending the drivinq privileges of the obligor. For any such certification, the clerk of the court shall charge the obligor a fee of $5 as provided in the Clerks of Courts Act. (b) If an obligor has been adjudicated in arrears in court ordered child support payments in an amount equal to 90 days obligation or more but has not been held in contempt of court, the circuit court may order that the obligor's driving privileges be suspended. If the circuit court orders that the obligor's driving privileges be suspended, it shall forward to the Secretary of State, on a form prescribed by the Secretary, an authenticated . document certifying the court's order suspending the driving privileges of the obligor. The authenticated document shall be forwarded to the Secretary of State by the court no later than 45 days after entry of the order suspending the obligor's driving privileges. .
2

Sec. 7-702. Suspension of driver's license for failure to comply with order to pay support. (a) The Secretary of State shall suspend the driver's license issued to an obligor upon receiving an authenticated report provided for in subsection (a) of Section 7-703, that the person is 90 days or more delinquent in court ordered child support payments or has been adjudicated in arrears in an amount equal to 90 days obligation or more, and has been found in contempt by the court for failure to pay the support. (b) The Secretary of State shall suspend the driver's license issued to an obligor upon receiving an authenticated document provided for in subsection (b) of Section 7-703, that the person has been adjudicated in arrears in court ordered child support payments in an amount equal to 90 days obligation or more, but has not been held in contempt of court, and that the court has ordered that the person's driving privileges be suspended. The obligor's driver's license shall be suspended until such time as the Secretary of State receives authenticated documentation that the obligor is in compliance with the court order of support. Whim the obligor complies with the court ordered child support payments, the circuit court shall report the obligor's compliance with the court order of support to the Secretary of State, on a form prescribed by the Secretary of State, and shall order that the obligor's driver's license be reinstated.

-18-

WHEREFORE, respectfully

The

Petitioner

and

Movant

herein,

Laura driver's

Walsh, license, for

prays that this court suspend Joe Walsh's

and for further relief, prayed relief of this petition, which

for in the final comprehensive is incorporated

prayer

herein by reference.

COUNT VI REQUEST FOR TEMPORARY RESTRAINING ORDER and PRELIMINARY INJUNCTION and FOR OTHER RELIEF

65. paragraphs verbatim

The one

Petitioner through 64)

restates
T

and as

realleges

the

allegations were

in

above,

if each paragraph

stated

in this Count VI.

66.

~ Laura requests

this court:

Restrain,

impound,

and attach all

cash, credit cards, line of credit, bank accounts, financial of any trusts accounts, and assets, as in which

and any and all other has an interest custodial other of any or

the Respondent trustee,
i

kind, set up

including for

a fiduciary, expenses under

or

educational including for cash

or in any his custody

capacity

interest, current accounting Further,

further

those

and control he provides said

in his a full
i

"Joe· Walsh of the

Congress" flow

campa i.qn until , and use of

activity

accounts

and

enter a jUdicial

lien against

all of Joe's assets

in the amount finally and

of the unpaid Order Joe

child support the

and other unpaid status guo

costs and expenseSi other

to maintain

as to all his accounting

assets

accounts,

until he provides

a complete

of the use of the funds

under his direction

or control,

or over which he has an interest.

-19-

67.

Laura Walsh has a right

to this

relief

because:

a.

She has a protectible arrearage, Walsh, available on and unpaid information from his

right at issue, medical and

namely the child expenses, significant

support and Joe funds

and other has

belief,

Campaign Account,

and other entirety

undisclosed within the

a:ccounts and interests, possession are as, at on and control

which are in their of the Respondent, of dissipation, and belief, example Joe but

Joe Walsh, and which and/or to loss, many on

imminent risk information

depletion is not

indebted of

creditors, information manager Evanston for

(by way of and belief, $20,000

limitation,

Joe WASH being sued by .h.i s campaign is for non-payment, and
i

that

Joe

Walsh's court and

Condominium has been said funds

foreclosed)

and this secreting

must protect otherwise

from his

dissipating,

wasting

the funds available

to pay the child

support

and expenses

arrearage.

b.

She will the

suffer set

irreparable harm if relief forth herein and for the

is not granted, fact that:

for

reasons

i.

That,

on information these

and belief, funds, Joe

if

the

court

does not

impound all secrete and

Walsh will funds

dissipate, in

otherwise

waste

the

available!

-20-

order to defeat the claims of his children, and Laura;

ii.

That Joe Walsh has refused to disclose his income to Laura as required by the Judgment; he may h0ve other assets and accounts, but Laura has no information

regarding the samej

iii. That Joe Walsh has a history of not paying his child support, his children's expenses his bills, or his other obligations;

iv.

That Joe Walsh may secrete, encumber, conceal, deplete or otherwise encumber the remaining campaign funds

unless an order is entered by this court restraining and enjoining the Respondent, Joe Walsh, and his agents and assigns, from encumbering, transferring, damaging,

depleting or Ln any manner dealing with the Campaign Fund, or any other accounts and funds in JOE WALSH's control;

c.

She lacks an adequate

remedy

at law where there are no other

assets

with

which

to

pay

the

child

support

arrearage,

expenses, attorneys fees; and other damages;

d.

She is likely

to succeed

on the merits where she can clearly

-21-

establish that: the arrearage moved to modify,

are judgments

I

and Joe has never

abate, terminate,

or in any way impair them; in the past, refused to provide evidence of

that the Respondent pay child support,

has been employed and refused to

employment,

or tax returns to show income available

for Child

suppor t r further, and or/disposing frustrate expensesi

Joe is, and will most likely be, dissipating of the campaign attempt to funds, collect and other assets, to child support and

Laura's

68.

That said restraining and upon the

order should be made returnable date, this Honorable and enjoining fund, Court

as soon should

as practicable

return

enter a preliminary from disposing accounts throughout and

injunction. restraining

the Respondent

of. any funds funds, and

from his campaign restricting and

or from any other said conduct

restraining

the pendency

of this action.

69. Petitioner without

That

the· Court

should

waive

the

requirement

that

the is

post a bond for the relief prayed

for where the Petitioner

funds to pay for same.

WHEREFORE Temporary herein,

(Temporary

Restraining

Order),

on the Count requesting the Petitioner

a

Restraining

Order,

and other Relief, prays

and Movant

Laura Walsh,

respectfully

as follows:

-22-

A.

For a Temporary Restraining Order and a Preliminary Injunction restraining and enjoining the Respondent, Joe Walsh, as follows: 1. Order the Respondent to immediately turn over any funds in his campaign fund or other account for child support arrearages and expense arrearages; Restraining and enj oining the Respondent, Joe Walsh from using any funds remaining in his campaign fund, or any other account, without an order from this court; That Joe Walsh be required to seek court approval prior to .expending any monies other that those reasonably necessary for his daily living expenses, or transferring any property or assets; That the Restraining Order so entered should be made returnable on the earliest available date, at which time a preliminary Injunction should be entered restraining and enj oining the Respondent from the aforesaid conduct during the pendency of this cause. That the requirement of bond be waived for good cause shown;

2.

3.

4.

5. 6.

Restrain, impound, and attach all cash, credit cards, line of credit, bank accounts, and any and all other financial accounts, ahd assets, in which the Respondent has· an interest of any kind, including as a fiduciary, trustee, or custodial of any trusts set u for educational expenses. Or any other reason, further including those under his custody and contro'l in his current "Joe Walsh for Congress" campaign; until he provides a full accounting of the activity and use of said accounts; and Further, enter a judicial lien against all of Joe's assets in the amount of the unpaid child support and other unpaid costs and expenses; Order Joe to provide a full accounting of all his as.sets, income, debts and liabilities, and expenditures, including the use· of his personal, family or educational or other trust funds, or other custodial accounts, etc., over which he has any fiduciary control or any other interest, including as a trustee, or custodian; business interests; and campaign funds; from the entry of the Judgment of Dissolution of Marriage (when he first failed to pay in full the child support he already owed, to the pr~sent day; For such other deems just. and further relief as this court in equity

7.

8.

-23-

AND counts

FURTHER,

(COMPREHENSIVE

PRAYER

FOR

RELIEF)

regarding Drivers

those License

for Child Support,

Tax Returns, Child

unpaid Expenses,

Suspension, herein,

and Recalculating

Support:

the Petitioner

and Movant

Laura Walsh,

respectfully prayer

prays this Court grant her the relief

in this comprehensive

for relief:

A.

Issue a Rule requiring

the Re sponderrt, Joe Walsh

to show cause, if civil contempt of for

any he can, why he should not be held in indirect this Court and punished Dissolution of marriage

for failure to comply with the Judgment entered by this court, and

the modified

child support orders

entered

subsequent

to the Judgmenti

B.

Enter

a Judgment

in

favor

of Petitioner,

LAURA

Walsh

and against in the

Respondent,

Joe Walsh,

for the arrearage and interest,

in child

support

total amount, principal $117,437.25,

as of November

I, 2010, of

plus any subsequent interest 2-1303

support overdue on the date of the to Code of Civil Procedure interest up to the

order plus statutory Sections 12-109 and

pursuant

and any additional

date of the orderi

C.

Find that Joe Walsh willful

is in indirect

civil contempt

of Court for his

failure to obey the Court's Orders, that his failure to pay cause or justification, and was wilful, and

was without compelling contumacious;

D.

Tha t the Court, upon finding Joe Walsh in contempt, of his driving privileges of the Illinois Marriage Financial 5/7-701 Responsibility 5/7-708, or limit such privileges and Dissolution

order suspens ion under Section 505 Act and Family Code, 625 ILCS

of Marriage

Law of the Motor Vehicle until the debt is paid;

through

-24-

E.

Restrain,

impound,

and
J

attach

all

cash,

credit

cards,

line

of and

credi t, bank accounts assets, includin~ in which

and any and all other financial Respondent trustee, has an interest

accounts, of any

the

kind, set

as a fiduciary, expenses.

or custodial

of any trusts

u for educational

Or any other reason, further in his current a full

including

those under his custody Congress" activity campaign;

and control he

"Joe Walsh for of the

until

provides

accounting enter

and use of said all of Joe's

accounts; assets costs

and Further,

a judicial child

lien against support

in the amount of the unpaid

and other unpaid

and expenses;

F.

Order other 2010,

Joe to turn over to Laura his tax returns and schedules, attachments immediately; for the years 2005, 2006. 2007,

and

2008, 2009, and

G.

Order debts

Joe to provide and liabilities, family or

a full accounting and expenditures, or

of all his assets, including trust

income,

the use -of his funds, or other

personal, custodial or any

educational etc.,

other

accounts, other

over which including campaign

he has any fiduciary as a
i

control

interest,
i

trustee, from -the

or

cus t.od i.an , the

business JUdgment

interests

and

funds

entry· of

of Dissolution

of Marriage he already

{when he first failed to pay in owed, to the present day;

full the child support

H.

That based

the court

recalculate

Joe Walsh's. child support

obligation,

on his new employment;

I.

Require costs

the Respondent,

Joe

Walsh Laura and

to pay the Walsh

attorneys

fees and and

incurred

by petitioner,

in the preparation

presentation

of this Petition;

J.

For such other ands further

relief -25-

as this court deems just

VERIFICATION Petitioner, Laura Walsh, being first duly sworn, states under oath that she has personal knowledge of the facts and statements alleged in the foregoing Pleading and that they are true and correct, except for those stated to be on information and belief, and those she believes to be true and correct.

~4h
Lt
day of

~~~

,~~

sworn to before

me this

1uL~~~

I

l!J.l>

My commission

expires:

o'l.~ t· Jot'f t

ATTORNEY

CERTIFICATION

Ir JOHN A. COLADARCIr attorney for the Petitioner, Laura Walsh in the above-captioned matterr hereby certify that I have read the foregoing pleadingr and after making reasonable inquiryr to the best of my knowledger information and belief, I find said pleading to be well grounded in factr warranted by existing lawr and not interposed for any improper purpose

One

of her

attorneys

COLADARCI AND CoLADARCI - #37619 - ATTORNEYS FOR PETITIONER - 155 NORTIIMICHIGAN -CHICAGO, lLLlNors 60601 - TEL. 312-616-4272 - FAX312-861-1874

AVENUE, SUITE 375

-27-

9(1705/031134/WKB/mb IN CIRCUIT COURT OF' COOl{ COU!\JTY, ULJNOIS COlJNTY"DEP AR.TMENT~ DOMESTIC RELATIONS Dr) VISION
IN" RE.

rae

THE M.AR.RlAG:E~ OF: LAURA WALSH,

)
) '. )

.Petitioner,
and

)
)

) Case No. 02 D 230912
)
)

WILLJ.AM WALSH.
Respondent,

) ) OF MARRIAqE .
of Marriage of the being .

l:QJlJGMENT FOR DISSOLUTION . .

THIS CAUSE coming on to be heard on the Petition fbr Dissolution Petitioner, represented Respondent LAURA 'w'ALSH) and the Respondent, WILLl~f

·WAI.Sa Petitioner

by ANNE M, CO~ARCI

of the law firm or COLADAR::1

and COLADARCI,

having been present in open court and represented

by WTI1 lAM K .. ;BASS' of the

law film ofROSENFEL:P.
for hearing pursuant Petitioner

R.OTENBERG, HAF'RON &'SRAPIRO, and ·:tas causing coming on

to the agreement of the parties~ the Court having hea rd the testimony of the
and being otherwise

and Respondent

fully advised in the premises,

DOES FlND

THAT:
. 1. 2. The Court has jurisdiction of the parties hereto and the subject matter hereof. LAURA 'WALSH was a resident of the County of Cook, Stute of Illinois, for mare of MIIITiage, and has been a

than ninety days prior to the filing of her Petition for Dissolution . resident . preceding 3. period of the County of Cook.

State of Illinois for a period in excess of ninety days next

the making of these findings. WIlLWv1 WALSH was a resident of the County of Cook, State of Illinois f'Dra the filing of the Petition for

in excess of ninety days next preceding

Marriage, and has So resided for ninety days prior to the making of these findings.

9 121'3E

3::JI..:l..:lD X.3Q3.:f

j;o'3Ep-SLv-LtJ8

4.

The parties hereto were lawfully married on March 21, 1927 in Davenport, Iowa

and said marriage was duly registered in Scott County, Iowa. 5.

ThTee (3) children were born to the parties during the course of the marriage)

namely JOSEPH MIC!-L~L WALSH., born August 8, 1981) .MEGAN :F.YAN WALSH, born December 5) 1990 and IIATRlCK CHARLES WALSlt born Beptember :W) 1994~ DO children

were adopted by the parti es and the P etitioner is not presently pregnant,

6.

Certain irreconcilable differences have arisen .betWeen the :;'Iarnes! all attempts at

reconciliation have failed and further attempts at reconciliation would not ':Ie in the best interests
of the famlly; the pmie€ have been separated for a period in excess of

M.:i J~

~.' .'

' ...
. -

~twO(2)Y_~'

separate and apart

smce : i:l~V'\I~

\ , ~,
J

.

itlc

~~,;the)tttiesh'V~beenliving

J

..
for

7.
Dissolution

LAURA W~SH
of Marriage

has proven the material allegations of her Petition fur
competent and relevant evidence, and a Judgment

by . substantial.

.

. Dissolution of Marriage should be entered herein.
g,The 2004 and parties have entered into a Marital Settlement Agreeneat dated March 29,

a Joint

Parenting Agreement dated March 29~ 2004 regarding

the lr respective rights and

responsibilities arising out of their marriage, that said Marital Sett1emenl Agreement and Joint
Parenting Agreement have been received into evidence and have been apt roved by the parties as . a

fair and satisfactory

resolution,

and the Court has considered

and ;lpproved said Marital and the Joint Parenting

Settlement Agreement

as an equitable resolution

and not unconscionable

Agreement has being in the best interest of the: parties three (3) minor children, and that said agreements make provisions which include, but are not limited to, provi.tions for the children's, apportionment of dr: bts and the disposition dated

custody. the children' s support, spousal maintenance, of property, The parties are desirous of incorporating

said Marital Settlement Agreement

-=1.-.,r -l-ln

'x'-=1rT-=I-l

QP:vT

~T~7./v7./TT

.. ~. March 29, 2004 (attached hereto and made a part hereof as Exhibit BAt') sud-said Joint Parenting Agreement dated March 29. 2004 (attached hereto and made a part hereof as Exhibit "B~') within this Judgment for Dissolution of Marriage and that said agree.mmts are as 1.111ows:

3

MARITAL TIDS AGREE1v.[ENt made

SETTLE:MENT and entered

AGREJI£MENT

into' this 29th. day of March, 2004,

by and

residents of the County of Cook and

State of Illinois. WITNESSETH

WHEREAS, A, County, The parties were married on March 21) 1987; sind marriag e is rogist~ed

in Scott

Iowa..

e.

Three (3) children

were bom to the parties
J

during the course of the marriage.
ItYAl\r WALSHl bom

namely JOSEPH MICHAEL December

WALSHl

born August 8 1981, MEGAN

5, 1990 and PATR1CK CHARLES WALSH. born September 20. 1994; no children

were adopted by the parties and the Petitioner is not preseatly C. attempts
,

pregnant.
all

Unfortunateand

irreconcilable

differences

have arisen b etweea the parties,

at reconciliation have failed, further. attempts at reconciliation would not be in the best
broken. ' .

interests of the family unit, and the marriage is irretrievably D. The Wife has filed a Petition for Dissolution

of Marriage m the Circuit Court of entitled "In re the Marriage of Laura said case remains pending and

Cook County. Illinois known as case number 02 D 230914 Walsh. Petitioner, and William Walsh" Respondent";

undetermined, E.

as no Judgment or final order has been entered. The Husband has employed. and has had the benefit of co .msel of'iNILLIAM HAPRON & SfIAPIRG ("RRES'j K.

BASS of ROSENFELD,

ROTENBERG,

as his attorney. The

Wife has employed and has the benefit of counsel of ANNE M. COLADA i:\.CI of the law firm of COLADARCI and COLADARCI C·COLADARCr'). Both parties have had the benefits of the
:0

advice. investigation

and recommendation

of their attorneys wifr.. reference

the subject

matter of

..:

this Agreement.

Bach party represents, and warrants that he or she has fulh: disclosed and is fully estate and income, both dir :dly and through the

informed of his or her wealth, PropertYl furnishing of financial data. to counsel,

WHEREAS, both parties expressly state that they have freely and voluntarily entered into this Agreement of their own volition. free of any duress Dr coercion and with the full knowledge. of each and. every provision contained ill this Agreement, and the consequences thereof; and the parties turther acknowledge
(a) (b) The respective

that their attorneys have carefully explained:

legal rights and duties as between the: parties;

The range of what the Court. may order

'a contested matter;
(0) The legaleffect

i:: called

upnn to decide the case as:

of each provision in this Agreement:

and

That each party expressly states that no representations

.nas been. ttl ade to him or to her by

the other party or his ox her attorney other than what is contained in this AJ jreement, WHEREAS. both the Husband and Wife have decided not to jursue
Dr

complete the

taking of formal discovery of each other's respective wealth. and assets, induding but not limited

to all depositions, interrogatories, demands for production, or other

f011I:l5

of discovery iD.· the

aforementioned case of "In re the Marriage of Walsh," other than thai which has been fully performed, Both the Husband and Wife fullyunderstand the ramificationr
i

of their failure to take

the aforesaid formal discovery and have been so informed of these ramifications.
the time of Judgment. either party has failed to disclose, or

In the event, at

has secreted, hidden or concealed any

assets, income, property" business interests or the like, then that party shah immediately transfer, payor otherwise reimburse to the other party .fifty percent (50~1o) of the "V nlue of said asset as of the date of the entry of the Jud~ent,
necessary attorney's

and

shall be solely responsible ::01' tho reasonable and
including

fe(lS and costs of the other party to enforce this paragraph)

5

90

39'i1d

38I..::l..::lO X:3a3..::l

p9Ev-SLv-LPB

reasonable

costs and fees incurred in the investigation

and discovery.of

uaid undisclosed assets,

property income and the like. WHEREAS,
proceedings :in

without any collusion as to the pending proceedings, or any other'
of the parties, and

that may.be filed between the parties effecting the maritalstatus

the interest of avoidingprotracted

litigation, the parties cons.der it to be in their respective best
between

interest to settle, adjust and compromise
maintenance,

themselves now and forever, the matters of
of property, rights of the parties,

child custody, cluJ.d support, the settlement

the

payment of attomey's fees. debts, the disposition of all claims arising by virtue of the marriage ci
the parties hereto on Dr to any and all property real, personal, or mixed tangible or intangible
I

now, heretofore or hereafter owned or possessed by the other party heeto, including without
limitation homestead,

of the foregoing, all inchoate and other rights of dollar in contesy and all rights of
inheritance, dissent, distribution, and community interest in survivmg spouse's

award.
NOW THEREltORE
f

in consideration

of the; foregoing
.

and in j urther consideration of
,

the mutual and several covenants contained below> and for other good m1;dvaluable consideration by each to the other delivered. the receipt and sufficiency ofv,hich is hereby acknowledged,
parties do hereby freely and voluntarily agree by and between themselves
I.S

the

follows:

ARTICLE} ;RESERVATION OF LITIGATION 1.1
Wife reserves

'RIGHTS

This Agreement is not one to obtain or to stimulate dissolution of marriage, The
the right to prosecute her pending action and defend :l.Dy action, which the

Husband may c?rrunenc~;. The Husband reserves the right to prosecute an)' action for Dissolution of Marriage or declaration of invalidity of marriage, which he may deem n ecessary or proper~ and

to defend any action which the Wife has brought or may bring.

ARTICLE II MUTUAL WAIVER OFlVlAINTENANCE 2,1 The Wife agrees that she shall waive andrelease any and a.l right she may have in

and to maintenance and support from the Husband, whether past, present, :~rfutl.ll'e.
2,2 The Husband agrees that he shall waive and release any an Ii all right he may have
0:'

in and to maintenance and support from fhe Wife) whether past: present, 2.3 make
barred,

future.

Both parties acknowledge that by waiving maintenance ;hey cannot hereinafter (formerly known as alimony) against the ot her and same is forever

a claim fo!"maintenance

. ARTICLEID
CUSTODY AND VISITATION
.

-

The Joint Parenting Agreement dated March 29~ 2004.(and attached to and incorporated in the Judgment for Di~:solution of Marriage as Exhibit "B") contains 1h:Jfull agreement of the parties, and is expres.s1yinccrpcrated into' this Article .III. E-oth parties intend that said Joint ~aret1ting Agreement become the final Order of this Court effective upon the entry of the Judgment for Dissolution of Marriage. ARTICLE IV CHILD SUPPORT The Joint Parenting Agreement dated March 29,2004 (andattac.lH:dto and incorporated in the Judgment for Dissolution of Marriage as Exhibit "B") contains tho full agreement of the parties, and is expressly incorporated into this ~cle TV. Both parties intend that said Joint

Parenting Agreement become the final Order of this COUrt effective .ipon the entry of the Judgment for Dissolution of Marriage.

7

ARTICLE V

CHILDREN'S E)""'PENSES
The Joint Parenting Agreement dated March 29~2004 (and attached to and inc~rporated in the Judgment for Dissolution of Marriage as Exhibit "B") contains th,:',full agreement of the parties, and is ex-pres,sly incorporated into this Article V. Both parties intend that said Joint

Parenting Agreement 'become the final Order of this Court effective .tpon the entry of the Judgment for Dissolution of Marriage, ARTICLE VI INSURANCE AND MEDICAL EXPENSES

The Joint Parenting Agreement dated March 29. 2004 (and attached to and incorporated
in th~ Judgment for Dissolution of Marriage 'as Exhibit "B'') contains the full agreement of the parties, and is expressly incorporated into this Article VI. Both parties intend that said Joint .Parenting Agreement become the .final Order of this Court effective .ipon the entry of the

Judgment for Dissolution of Marriage.
ARTICLEvn EDUCATIONAL EXPENSE~ The Joint Parenting Agreement dated March 29~ 2004<an.d attached to and incorporated' in the Judgme:nt for Dissolution of Marriage as Exhibit '''B~') contains thi: full agreement of the . parties. and is expressly incorporated into this Article VILHoth , parties intend that said Joint

Parenting Agreement become the final Order of this Court effective upon the entry of the Judgment for Dissolution of Marriage.

8

, AR'TJa:E VITI SETTLEMENT 8.1 OF PROPERTY F~GRTS

During the course of the marriage, the parties acquired a marital residence

commonly knownas 2110 Harrison Street. Evanston, Illinois (sometime: the "Property"), The

Property is currently undercontract

for sale.

The parties vv\lill receive: an equal distribution
Upon closing of the

(50%/50%) of the net sale proceeds subject to the following allocations,

Property, and after retirement of the first mortgage to Option One Mortgage, Company in the approximate amount of $500,000.00 and the second mortgage to' Anne Berkley in the

approximate amount oi$lg)OOO.oO) certain joint mal:ital debt will be paid from the uet proceeds. -Additionally, certain debt assigned to each party) individually, will be paici from their share of the net sales proceeds. All debts and/or payments) as outlinedbelow, wil'. be made prior to the

distribution of the net sales proceeds to the parties:

Joint Marital Debt A.
B. C. D. E. P. G. H. I. 1. K. 8.2

Loyola High School
Saint Athanasius School Internal Revenue Service Burke Warren MacKay & Serritelia. RC. . Dr. Lee Graber Sallie Mae Financial Wells Fargo Financial Steve Walsh Dr. Susan Graber
AT&T

$6,670.00; $6.000.00l; ·$5,000.00; $1,300.00; $2,500.00; $6,000.00; $12,500.00; $35,000.00; $2,000.00;
$1)300.00; and $205.00.

Evanston parking tickets

Husband's share of the net sale proceeds shall befurther reduced by: A. $J,OOQ.QO, which shall be paid directly from Husl and's share of the net

1 The total debt to Saint Athanasius School is in excess of $6,000.00, It: s the patties' intention to defray that amount by scholarship, If a scholarship is r.ot availab. e or if only a partial scholarship is available. the debt to Saint Athanasius shall be paid in full at the time of closing before any distribution to tho parties.' ,

131

3!:J\;;,d

913'3E

3;)I..:I..:I0 X3G3..:1

sale proceeds to the Wife as contribution to and for .rer attorney's fees,

B.

$:1,952.10, which shall be paid directly from Husband's share: of me net sele proceeds directly to Nicer Gas as and for past obligations for the gas bill on the marital residence;

C.

Husband's obligation to Commonwealth Edison, which shall he paid d5rect1y from ,Husband'Js share of the: net sale proceeds directly, to
Commonwealth

Edison as and for past obligations

for the electric bill on

the marital residence;

D.

Husband"s obligation

to the Evanston, 'Water Depa:'tment

I

which shall be

paid directly from. Husband's share of the net sale ::')toceeds directly to the Eva:nst~n Water Department as and for :past obligations for the water
Oll

pill

the marital residence;

E.

$1~489.88. which shall be paid directly to the Wife from the Husband's share of the net sale proceeds as and for resolrtion dissipation; of any. claim of,

F.

$:lOO.OO),which shall be paid directly to the City of Chicago Department of

Revenue from the Husband's share oftbe net sale proceeds as and for his
past and present parking tickets and/or moving violutions; and

G.

Husband's obligation to Loyola High School, whicu shall be paid directly
from the Husband't share of the net sale proceeds 'icoLoyola High School

for the balance of past due tuition,
H.

$17~g64.75 which shall be paid directly from the ::iusband's share of the
net sale

proceeds

to Rosenfeld,

Rotenberg) Hafron & Shapiro

for

attorney's fees and costs.
10

3CJI.::L:lO X3G3.:l

"P'3EV-SLP-L"PS

8.3

Wife's share of the net sale proceeds shall be further reduced by:
A,

$4,000.00.

which shal1 be: paid directly from the ';Vife's share

of the

net

sale proceeds

to the Husband as and forequalizati

an of the equity in the

net sale; proceeds costs.

to Colada:tci and Coladarci

I::or

attorney's fees and

ARTICLE IX

PRRSONALPROPERTY
9.1 agreed upon. 9.2 automobile The Wife shall receive The Wif~ and Husband shall divide the partiea" personal properly as previously

as her

sole and exclusive property the 2001 Honda Civic

and the Husband shall immediately transfer title to Wife UPOll entry of the Judgment.

Upon Husband's

vacating' the Property and simultaneously

commencing

I

:hild SUpport payments,

the Wife will be responsible for the monthly cer payments on the vehicle. 9.3 intangible The Wife shall retain as her sole and exclusive property anyand personal property currently in held in her

all tangible and

Indtviduel name innluding, but not limited
ffiA's, CD's, ·pension, deferred

to. checking .acccurrts, savings
compensation, Husband

accounts,

stocks, bonds,

profit sharing, and the like) free and clear of

any interest

I)f

the Husband

and file

shall execute any and all documents necessary to convey his interest therein to the

Wife.
9.4 and intangible

The Husband shall retain as his sale and exclusive property any and all tangible.
persona] property currently

in held in his individual nr.me including, but not

limited to, checking accounts,

savings accounts, stocks, bonds, IRA's, CD's, pension, deferred
11

3:)I..:l..:lOX3G3..:l

tr9Ev-SLv-LP8

compensation;

profit sharing, and 'the like, free and clear of.any interest of the .""ife and the Wife

shall execute any and all documents necessary to convey his interest fherei: :1, to the Husband. 9.5 The above and foregoing division of. property as set fbrth in Article IX is

contemplated and ..ntended to be a non-taxable division to beth Wife am: Husband of mutually i acquired property acknowledging their respective contributions to the accumnlated marttal estate

and as such is not a. sale: payment or transfer to secure a release of marital rights, but is a division
by and between the

parties ohhe marital property in which they have a common ownership and

mutually acquired during the marriage in accordance with Section 503(e) I:,fthe Illinois Marriage and Dissolution Act. Therefore, the above division of property

is a non-taxable transaction, not
asset

subject to gains or losses to either. spouse.

Accordingly, the basis of each individual

received in its entirety by 01'1e spouse or the otherin this diw~on will retain its present marital basis in the hands of the spouse receiving it
AR.TICLEX

TAXES 1001 The parties shall file Joint State and Federal Income Tax Retums for the tax years 2002 and 2003 and shall equally divide any refund received. assessment in connection
responsible with any joint

In the event of a deficiency

retum(s) associated 'with these returns, the party
through non-payment or underpayment of

for the deficiency

assessment

taxes shall

pay any and all amounts finally determined

to be due as a result of said a~:sessment(s) including.

taxes, interest, and penalties,

and all costs and expenses incurrel

in contesting

said

assessmenus),
ARTICLE XI MARITAL DEBT
1L 1 Both parties shall be solely and exclusively
12

responsible fOJ any and all debts and

"
I ;_-

I

liabilities which they have incurred in their individual names during the term of the marriage) not

otherwise disposed

of in Article VIII, and each party shall indemnify ard hold the other party

harmless from any and all claims made thereon.

ARTICLEXll
ATTORNEY'S 12.1 F:ffiES

'The Husband shall 'be solely responsible for all of his attomeys' fees and costs for
from the Wife.

this litigation. and waives any right of contribution

1.2.2

The Wife shall be solely responsible for all of her attomey'u fees and costs for this

litigation~· and waives 'acy tight $3~OOD.OO Husband that
12.3 and costs

of

contribution

from the Husband! ~I,)'ith the exception

of

will contribute

towards Wife's attorney's fees and costs.

The parties agree that each of them shall pay and defray an) and all remaining fees

due to thei! respective attorneys

at the

closing on

the: Property, trorn their share of the

net sales proceeds. 12.4

and 'before distribution to them of their share: of the net I)TOCeeds.,
has notified

COLADARCI

the: Wife of her right to hearing relative to the

outstanding fees: and expenses due and owing) as well as her right to be ret IFesented by counsel of her Choice other than COLADARCl relative to said fees and OM'., ~W""oiPt
of her invoice, she has agreed to pay COLADARCI Article VIII herein. 12.5 RRJIS has notified the Husband of his right to hearing relative to the outstanding the sum of $~,

and review
suant

_I

to

fees and expenses due and owing, as well as his

right to be represented by counsel of his choice

other than RRHS relative to said fees and costs, and after receipt and rev iew of h~s invoice. he has agreed to pay RRHS the sum of$17 864.75
j

pursuant to Article

vm herein.
to fees

12.6

'the parties have been further advised of their light to seek contribution
l3

1:>1

39\;;ld

::;;g9S

38I..:I..:IO X3G3..:l

j?9Ej::l-::;;L1?-Ltl8

and costs from the other party pursuant Dissolution

to 750 ILCS

5/51)3 of the Illinois Marriage

and

of Marriage Act. The parties hereby waive any right to contibution

other than that

provided in paragraph 12.2 of this Article.

ARTICL1tXIII ~HU=S=:eAN=..:;:..:.=D...:;!S;;..:RE=M=O:..:V:..:::.A=L~FR=. O=M=-T::..:H;;.::.E=M=A~:;RI=T.;;.;A;;:::;;L~:H!OME
13.1. The Husband agrees to remove himself from the marital residence on or before

April 1. 2004 provided that the Judgment for Dissolution of Marriage is er.tered prior to that date,
At such tirne as the associated

Husband vacates the Property; the Wife will be re sponsible for all costs
utilities,

'With the Property, including

with the EtXception I :,f the April mortgage

payment that will be paid at the time of closing. The parties will equally divide the Apri_lrent payment of $1,200 from their ten.an.t upon receipt thereof or at thedosin~ final accounting,
Property. unqualified

on the Property after a

or apply said rent payment towards the April 2004 me rtgage payment on the
not close on or before"Ma;;r I, 2004~ the: Husband has the
aODUT

Should "the Property

right to return to the marital residence,

Should the closing uot

on or before

May 1~ 2004) because the present
immediately the parti es. place the

buyers do not purchase} the Prop erty, the parties must

Properly for sale by owner or with a real estate brol cer to be determined by

d's obligations

as set forth in paragraph 13,1 of this

to the Property each weekday frc rn 8:00 a.m. until 6:00 p.m.) in order to conduct his business
school. If the Husband is Property within and care for tho minor children both before and after

'unable to be at the Property during this time, or i;. unable to arrive at the depart at 6: 00 p.m. at the .1~~sban.~.

at 8:00 a.m, aUd/or.

twenty-four(24) hours or as soon as reasonably pr_cabli~ ~
. l4 ~

\jtYYl~. ~.) be provided

must notifY, the Wife access to

"

th~ marital residence on, an "as

needed" basis for the purposes of obtainii:Lg work files necessary
Said access shall be during a The

.to the operation of his business prior to the closing on the Property, mutually agreed upon time . access to the marital

between the Husband and the Wife.

II usband shall also have

residence in order to pack and/or remove those items the; parties delineated or as otherwise agreedupon, Wife's bedroom. \Vhil:; present in the marital

in paragraph 9.1 above in Article; ~

. residence, the Husband agrees not to enter the

ARTICLE XIV EXECUTION CLAUSE 14.1 Each Of the parties agree to execute and acknowledge, upon the effective date of
instruments necessary or proper to

this Agreement. good and sufficient

ve st the titles and estates

of the respective parties, as hereinabove: provided, and thereafter, at any time from time to time, to execute and acknowledge

any ana all document which may he necessar ~{ proper to carry out or

the purposes of the agreement arid to establish of record the s\)le and set:erate ownership of the
several properties of said parties in the manner herein agreed and provided,

If either party for

any reason shall fail or refuse to execute any such documents. tuen this Apeement
hereby expressly declared to. constitute a full and

shall, and it is

effective p;esent transfer, assignment and
assigned, and conveyed and a designated to be

conveyance of all rights hereinabove

designated

to be transferred,

full, present and effective relinquishment

and waiver of all rights hereinabove

relinquished and Waived,
ARTICLE :A"V GENERAL PROVISIONS 15,1 Tho Wife covenants and agrees that, except as is otherwis L'; provided herein, she

. shall, and hereby does, waive, remise, and relinquish
l5
:It 38'ii'd

any and an claim

01:

right, title or interest

90SE

381.:l.:lO

1<303.::1

which she now has, or might hereafter assert, against the Husband or his property, whether real. personal or mixed, by reason of the marital relationship previously existing between them) at for

any other reason.

The Wife's waiver shall include, but not necessarily be limited to, a waiver of

any and all.rights to maintenance

(formerly known as alimony), homestead.rdower,

inherttance

and succession.
15.2 The Husband covenants and agrees that, except as is otherwise provided herein.

. he shall, and hereby does, waive, remise. and relinquish which he

any and 'all claim 1 :,f right, title or interest

now has. or migbt hereafter assert, against the Wife or her Jll"OPerty, whether real,
previously existin!~ between them. or

personal or mixed. by reason of the marital relationship

for

any other reason. 'the Husband's waiver shall include, but not necessarily ee limited to, a waiver
• • I.

of any and all rights to maintenance
and succession.

(formerly known as alimony), homesn rad, dower. inheritance

15.3
waive and

Except

as. is otherwise: provided herein, each of the parties uhall, and does hereby.
or executor of the e state of the other party

relinq"Cdsh all rights to act as administrator

an.d to inherit by intestate succession or

any of the property of which the other party ,may die. seized This Agreement shall operate as a in

possessed (should either' of the parties die intestate).,

relinquishment

of all right of the surviving party hereafter to apply for lett! in; of administration

any form. and the estate of such deceased party, if he or she dies intestat l~. hall descend to the s heirs at law of such deceased 'Patty. in the same manner as though the parties had. never been

married. Each of the parties, respectively. reserves the right to dispose, by testament or
otherwise, of his or her property in any way that he or she may see fit, without any restriction or

limitation, whatsoever;

except that this' provision shall

110~operate

nor shall it be construed as a

waiver or release by either of the obligations of the other to fully compl Y with the terms of this
Agreement.
16

Nov 24 10 04:27p p.1

15.4

To the fullest extent permitted -by law, except as is otherwise provided herein, "

each of the parties shall, and hereby does, forever relinquish, release, waive, quit claim and grant to the other (or his or her heirs, personal representatives and assigns) all rights of inheritance, descent, distribution, community interest, and any and aU other light, title, claim. interest, and estate as Husband or Wife. widow or widower, or otherwise by reason of the marital relationship previously existing between them under any present or future law, or which he or she otherwise "has or might have or be entitled to claim in, to, or against the property and assets of the other, real, personal, or mixed, or his or her estate, whether now owned or hereafter in

any manner

acquired by the other party, whether in possession of or :in expectancy, and whether vested or contingent, Bach party further covenants' and agrees for himself or herself, his or her heirs,

personal representatives, and assigns, that neither of them shall at any time in the future sue the other, or his or her heirs, personal representatives, grantees, devisees, or assigns, for the purpose of enforcing any and all of the rights specified in and relinquished under this paragraph. Each

party further covenants and agrees that in the event any suit "shall be commenced, this release, when pleaded, shall be and shall constitute a complete defenseto instituted by either party. Each party further covenants and agrees to execute, acknowledge and to deliver, at the "request of the other party, his or her heirs, personal representatives, grantees, devi~e,es or assigns, any or all such deeds, releases, or other instruments and further assurances as may be required as reasonably requested to effector· to evidence the release, waiver, relinquishment, or any such claim or suit so

extinguishment

of all rights so released, waived, relinquished and extinguished under this herein contained in this paragraph or in this

paragraph; provided, however, that nothing

Agreement shan operate or shall be construed as a waiver or release by either party to the other of any obligation on the p art of the other to comply with the provisions of this Agreement

11/24/2010

14:42

FEDEX OFFICE

5.

PAGE

02

_.-;"'

15.5

The parties acknowledge

that they have been separately advised by their attorneys

that there may be- certdn tax. consequences pertaining to these agreements, that their attcmeya have not furnished directed
C01J11Sei

ta";~ advice

with respect

to these agreements, tax advice from

that the patties

have been

and advised. h: I obtain ~dependent

a qualified

tBJ;; accountant or a tax

prim' to slgninl; this Agreement and that they have had 1:h.eopportunity to do so. .
15.6

This inntrument contains the whole, entire and complete agreement made of the
or her respective

parties; has been exalt Ined by each of the parties, assisted by counsel ofhis

choice; and is believed by each of them to be-fair, just and equitable in allrespects, 15.7
executors;

This Agreement shall be binding upon and shall inure to the benefit of the heirs,

Ild1:)linistrah:rs~ assigns, devisees and grantees of each of the parties. That if either of the parties breach any of the provisions
to

15.8

of this Agreement; the

breaching party shall be obligated

pay all attorney's fees and costs incurred by the non-

breaching party incurre :d.in his or her enforcement of this Agreement,
15.9 Each

0:: the parties in order to protect the privacy of the othez:, agrees not

to

publish or disclose t1:w terms of this Marital Settlernmt Agreement without the clear necessity to .
do so. 15.10

This Ajreement

shall become

effective and binding upon the parties only upon

the entry of a Judgmei: t of Dis sol' at ion of Marriage between the parties. , ' IN WITNESS· WHEREOF, the

parties have set their hands and seals. the day and date

first above written.

18

11/24/2010

14:42

847-47~'" ,4

FEDEX OFFICE

'5

PAGE

03

WHEREFOREJ A. marriage dissolved. B. was entered

IT IS RE,REBY

ORDERED

ADJUDGED

ANJIl DECREED:

A JUdgII' ent for. Dissolution of Marriage is awarded to the parties, dissolving their
and the bonia of matrimony heretofore existing between the parties are hereby

The parties are bound by the terms of the Marital Settlement

Agreement which into
for

into on Murch 29,2004,
md both

and the Joint Parenting Agreement which was entered are hereby incorporated into th{s Judgment

on March 29~ 2004, Dissolution

Agreements

of Matriag, as if'set

forth herein verbatim.

C.The

parties are awarded joint custody of the minor children, JOSEPH, MEOAN of the attached Joint Parenting Agreement

and PATRICK. subject to the terms and conditions
dated March 29J 2004, C. This
CCI~rt

shall retain jurisdiction Agreement

of this matter to enforce the provisions

of this

Judgment and the Mai,tal Settlement

and Joint Par~tin.g Agreement incorporated

therein.
D. The W:fe shall resume her maiden name of McCleave if she so desires.

ENTER:

JUDGE

MAl? 292004 GRACE a/~~Gt".
(LEI?"1e 1

ROSENFELD,. R01fENBERG1 IlAFRON & SHAPIRO, #90705 Attorneys for Respo ndent 221 N. LaSalle Street, Suite 1753 Chicagc, Illinois 61: 01 6 (312) 372--6058

i19,2004 alsh Parenting Agreement: Final age 1

JOINT PARENTING This agreement made this Walsh (the parents).

AGREEMENT

M day of March 2004 between Joe Walsh and Laura
ARTICLE I

CUSTODY AND VISITATION 1.1. Joint Custody. Each party is a fit and proper person to have legal custody of the minor children, Joseph Michael, Megan Ryan and Patrick Charles (collectively, "the Children"). Accordingly, the parties shall have joint legal custody of the minor children. The Mother shall have residential custody of Megan and Patrick. Father shall have residential custody of Joseph. Father shall pay to Mother guideline child support for Megan Ryan and Patrick Charles, 28% of his net income from all sources pursuant to 750 ILCS 5/505, without an offset from Laura, and regardless of the split custody of the parties' oldest child. 1.2. Mutual Acknowledgment. The parties hereby acknowledge the needs of the children for continuing contact with both parents and the need for both parents to participate in the important events and decisions affecting the life and well being of each child. Accordingly, . the parties shall cooperate in scheduling and' implementing each child's educational, religious, and social activities and health care so as to provide each child with an environment that promotes healthy physical, mental, emotional, and social growth and development. The parties shall also use their best efforts to foster the children's love and affection for both parents and to attempt to reach an agreement on all-important questions that require joint decisions by the parties. 1.3. Joint Parenting Provisions. The parties joint legal custody of the children shall be subject to the following tenus and conditions: A. Parental Rights and Responsibilities. Each Party shall have the obligation to provide necessary supervision and parental guidance for the children while in their care and each Party is authorized to make all day-to-day decisions affecting the child in that party's primary care, without prior notification to or consent of the other party. In all other respects, a party having primary care and residential custody of a child shall not be construed to give that party any greater rights or responsibilities than the other party. B. Joint Decisions. Without regard for any provision hereof to the contrary, the parties shall jointly decide all major issues concerning a child's education, religious training, and extraordinary health care.

Parenting Agreement: Final
2

C. Mediation of Disputes. In the event the parties are unable to agree on any issue requiring a joint decision, and in an effort to resolve their disputes without litigation, the parties shall enter into mediation as to issues regarding the children. The parties shall refrain from litigating a disputed issue until after completion of the mediation process. A mediator's recommendation shall not be discoverable or admissible in any court proceeding. The cost of mediation, if any, shall be shared by the parties equally. D. Access to Educational, Medical and Financial Records. The parties shall have joint and equal rights of access to the children's records that are maintained by-third parties, including but not limited to educational and medical records, and the children's custodial accounts, and the parties named as custodian of such accounts shall provide statements to the other parent on an annual basis. E. Duty To Advise of Grades and School Functions. Each party shall promptly advise the other of the Children's grades and progress in school and of all school meetings, functions, and activities that are open to attendance by parents. Each party will promptly advise the other party of all extra-curricular activities and schedules. F. Weekly Visitation: Each party shall have all three children on alternate weekends from Friday after school to Sunday night at 8:00 p.m. Father shall have all three children one night during the week from after school on Tuesday, overnight, and shall take the children to school on Wednesday morning. Additionally, each party has the right of reasonable visitation with the children during the week and may see the children as often as the children or the Party would like upon mutual agreement of the Parties. It is the intention of the parties that as often as possible, the children shall be together during these periods of visitation. G. Holidays and Vacations. follows: 1.. Alternate holidays including New Years Day, Martin Luther King Day, Presidents Day, Memorial Day, Independence Day, Labor Day, Columbus Day, and Veterans Day and Easter. 2. Thanksgiving Day shall be spent with the Husband and the Wife shall have the Children the remainder of Thanksgiving weekend. The Parties agree that both parties shall see the Children on both Christmas Eve, and Christmas Dayan mutually agreeable terms. Half of Spring break will be spent with the Husband and half with the Wife. 3. Half of the children's Christmas vacation from school will be spent with the The Parties agree to divide holidays and school vacations as

29,2004 Parenting Agreement: Final
3

Husband and half with the Wife; subject to the provisions for Christmas Eve and Christmas Day, above. The parties shall alternate the first and second halves of the children's Christmas vacation. 4. Summer vacation: Each party is entitled to two weeks summer vacation with the children, either consecutive or non-consecutive. The parties shall agree to their respective dates by May 1, in every year.' . H. Cancellation of and Rescheduling Visitation. Each party shall give the other party not less than 48 hours advance notice of any change in schedules and will use their best efforts to reschedule that time with the canceling party.
L Telephone Access. Each party shall have the right to contact the children by telephone

while the children are in the other party's care. J. purposes States. In telephone Vacation Travel. Each party shall have the right to travel with the children for vacation outside the territorial boundaries of the state of Illinois and the continental United that event, the traveling party shall advise the other of the relevant dates, locations, and numbers of the children's accommodations during the vacation.

K. Duty To Advise of Addresses and Telephone Numbers. Each party shall keep the other informed of his or her residence address, home telephone number, place of employment, work address, and work telephone number. In the event either party travels out of town for an extended period of time, that party shall provide the other with a telephone number at which the traveling party may be reached in the event of an emergency. L. Remarriage. In the event of the remarriage of either party, the party remarrying shall have an affirmative obligation to make known to that party's new spouse the terms and provisions of this Article and to encourage the new spouse to comply with the intentions of the parties as set forth herein. 1.4. Grandparent Visitation. The children's maternal and paternal grandparents shall have rights of reasonable visitation with the minor children of the parties. 1.5. No Right To Remove Child from Illinois. A. Neither party shall have the unrestricted right to remove the Minor Children to another jurisdiction to reside therein on a permanent basis, without first obtaining the informed written consent of the other party or the approval of a Court of competent jurisdiction.
B. Leave to Remove the Minor Children from this jurisdiction on a permanent basis

be subject to and governed by Section 609 or any successive provisions of said Act. C. If either Party relocates to a location more than fifteen (15) miles from Evanston, the Party remaining within a fifteen (15) mile radius of Evanston has the right to sole custody of the children. Upon the happening of this occurrence, the minor children will remain in the schools they are presently attending until their graduation, or unless otherwise agreed to by the parties. Upon the occurrence of such an event, a reasonable visitation schedule acceptable to each Party will be negotiated. ARTICLE II CHILD SUPPORT 2.1. Day-to-Day Support.
A. The Husband shall pay to the Wife, as and for the support of the minor children an amount equal to guideline child support pursuant to 750 ILCS 5/505. Based on Husband's current annual gross income of $121,000, ($10,083 per month), Husband shall pay, as and for child support for the two minor children Megan and Patrick, the sum of $2,078.44 per month commencing April 1, 2004, and continuing on the first and the fifteenth day of each calendar month thereafter. The April 1, 2004 payment, representing Fifty percent (50%) of the Husband's monthly child support obligation, shall be paid directly by the Husband to the Wife. All subsequent child support payments shall be paid directly from his employer pursuant to an order of withholding. Said amount is based on 28% of Husband's net salary income calculated pursuant to 750 ILCS 5/505. Said amount shall be paid pursuant to an order of withholding .§>T>'ed his employer. The parties acknowledge and agree that there shall be no child support on offset based on the residency of the parties' oldest child, Joseph with Husband. ..Qhild Support will be adjusted to r£ile.cLinCJ:eas~s in Husband's salary, and th~~llJJ.li1?~ill'l~~""T;'W"i;

1]22,~~ and sta~."!~,i~§~iJn ..~~~.~~~;~Q~Tll.1?j!~X~~S;~_o~ .th;jfiTilg \ thereof. Tlw-~QQ.p.enUe to. exec1!~Yl.St.d...ard.f<~ . mcrease m montE!Y_. ~LLte.tro?-£!:iv~ ... tQ-1b..f_£~teofru.).y.xai§.~ In addition, the Husband shall pay, pursuant to statute, 28% of all other net income received by him, including but not limited to any bonuses, consulting fees, or any other income in accordance with 750 ILCS 5/505 and 5/510, and shall pay Wife said additional child support WIthin 15 days of the receipt thereofx.The parties shall -rJ.f\ / Vv cooperate to enter a modified child supportupon the emancipation of Megan to 'reflect husband's child support obligation in accordance with 750 ILCS 5/505 for the remaining minorchild, unl-e~St\v..Sb:. . . ~0'l~":> t, fH?t 1. ( ,B. Childr~n'~ automobi~e insu~an~e: Husband shall be solely respons.ible fO.rthe cost of s.e-e.~~ h. yv "Joseph s automobile 1l1su~ance,including msurance for Jos.eph's car. ~~.~ .h dEJ:~a:htN 601't-U.~50Y\.jubt<!!. c,...,,-Ve.Y' ~ '" J"'I'Y(..<. ..... '-..,U') " 'hCLu devq o.""-} ~J{L..-Y ~,\.J'C °'7'lll ...J 1v 00'-'-<.171, '!> v ~ 0.;::.... ~ ~~ ~ '-O'f" 9"\ CIt C. Extracurricular expenses: Once the parties' son, Joseph is emancipated, the parties ~ ~hal1 share equally the costs of Megan and Patrick's extra-curdcular expenses: From the date of v' \j

VV/

'1

29,2004 alsh Parenting Agreement: Final page S

the entry of the Judgment until Joey is emancipated pursuant to paragraph F., below, Wife shall be solely responsible for Megan and Patrick's extracurricular expenses, with the exception of summer camp or programs, which shall be shared by the parties equally. Husband shall be solely responsible for Joseph's extracurricular expenses, until Joseph is emancipated. D. Respective Obligations. Except as otherwise provided to the contrary in this Article III, the Patties shall both be responsible for the day-to-day support of the children while in their care. Unless it is Father's visitation time with the children, Wife shall be solely responsible for the after school or day care of Megan and Patrick until the parties' son Joseph is emancipated pursu~nt to 2.1 F herein. Therea~ter, th~ part~es .shall equally share any after SCh~ 70r pay care ..0 costs incurred for Megan and Patrick while Wife IS at work

VJ;!W "'jp
'v~

p.l. shall commence, except as otherwise herein provided, upon the effective date of this Agreement and shall continue until the emancipation, as defined hereinafter, of the child in question.
E. Duration of Payments. The parties' respective obligations under paragraph
F. Emancipation Defined. For purposes of this Agreement, the term "Emancipation" shall be defined as the occurrence of the first of the following events: 1. The child's death; 2. The child's attaining the age of 18 years or completion of a high school educatiop, whichever later occurs, but in no event beyond the child's 19th birthday; 3. The child's maintaining a full-time residence outside the home of the parent having primary care of that child, exclusive of residence at a secondary boarding school, camp, or similar facility; 4. The child's obtaining full-time employment, exclusive of employment during school vacation periods; 5. The child's induction into the armed services of the United States or the National Guard; or 6. The child's marriage.

2.2. Children's Medical and Dental Expenses.
A. For as long as Wife provides health insurance for the parties' children, Husband

Agreement: Final

shall reimburse Wife for one-half (;,i) cost of difference between family plan and individual plans for medical and dental plans. Presently, Wife is paying $109 biweekly for Family Health insurance, and $34 per month for family dental; single biweekly health insurance is $40, and single dental is $12 per month. The difference is $69 per biweekly for health insurance, ($1,794 annually) and $22 per month for dental ($264 annually). Husband's 50% share is $1,029 per year, or $85.75 per month. The April 1, 2004 payment, representing fifty percent (50%) of the Husband's monthly contribution for the children's health and medical insurance shall be paid directly by the Husband to the Wife. All subsequent health and medical insurance payments shall be paid directly from his employer pursuant to an Order of Withholding. B. All ordinary and extraordinary medical and dental expenses not covered by insurance incurred on behalf of the Children shall be shared by the parties equally. Each party shall reimburse the payer within 14 days of demand. C. Duration of Obligations. The parties respective obligations under this paragraph 2.2. shall commence on the effective date of this Agreement and shall continue, as to the child in question, until the child's emancipation, as hereinabove defined, provided that if the child pursues a college, university, or vocational school education, then the obligations of the parties as set forth in this ·paragraph"lY.2.shall continue until that child's completion or discontinuance of the educational pursuit, but id{f~event ~ha10hese obligations continue beyond the child's 23rd birthday.

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D. Definitions. For purposes of this Agreement: 1. The term "extraordinary medical and dental expenses" includes, but is not limited to, expenses incurred for operations, treatments, medications, and services rendered as a result of accidents, illnesses, or conditions requiring hospitalization or extended care and treatment; ophthalmologic and optometric care and treatment, including the cost of glasses or contact lenses; psychiatric or psychological care and treatment; orthodontia and major dental work; and the like. 2. The term "ordinary medical and dental expenses" includes, but is not limited to, expenses incurred for routine' medical or dental examinations, services, and treatments; or for services and medications required in the treatment of common or minor accidents, illnesses, or conditions. E. Advance Notification. A party's obligation to pay extraordinary medical and dental expenses is conditioned on being notified by the other party before incurring any extraordinary medical or dental expenses on behalf of a child. However, advance notification shall not be required in cases of emergency in which delay may imperil the health or safety of the child in question.

Agreement: Final

F. Resolution of Disputes. Except in cases of emergency, each party may obtain a second opinion, at his or her own expense, as to the medical or dental needs of a child. In the event the parties are unable to agree on the extent of their respective obligations under this paragraph 2.2., on the appropriate classification of a medical or dental expense incurred on behalf of a child, or on the extraordinary medical or dental needs of a child, whether before or after incurring an expense, the issue shall be submitted to mediation in accordance with the provisions of subparagraph 1.3.C ofthis Agreement. G. Health Insurance. The Wife shall maintain health, hospitalization, and major medical insurance coverage for the benefit of the children. The Wife shall provide the Husband with an insurance identification card for the benefit of the Children. In the event Husband takes a position in which the heaith benefits are more comprehensive than those currently provided by Wife, then Husband shall maintain such insurance and provide Wife with an insurance identification card for the benefit ofthe Children.

2.3. Life Insurance for the Children. A. Required Amount. Both Parties shall secure and maintain insurance on hislher life, having unencumbered death benefits in the amount of $250,000, for the benefit of the children of the parties. B. Beneficiary Designation. Within 30 days of the effective date of this Agreement, each Party shall execute and deliver all documents necessary to designate the other Party as beneficiary of the foregoing insurance, not individually but solely as guardian of the children. C. Duni.tion of Obliga.tions. Upon the occurrence of termination events as to all children of the parties, the Parties' obligations under this paragraph 2.3. shall forever cease and terminate. D. Termination Event Defined. For purposes of this obligation to secure life insurance for the children, a "termination event" shall be defined as the emancipation of the child in question, as defined in subparagraph 2.l.F. of this Agreement, provided that in the event that child pursues a college, university, or vocational education, a termination event shall be deemed to have occurred upon the child's completion or discontinuance of that educational pursuit or upon the child's attaining the age of 23 years, whichever occurs first. E. Future Borrowings. The Parties represent and warrant that the amount of death benefits required hereby is and shall continue to be in excess of any and all policy loans. Henceforth, and except as otherwise provided to the contrary herein, the Parties shall refrain from borrowing against or encumbering this insurance to the extent that the borrowing or

Agreement: Final

encumbrance would reduce the death benefits below the amount required by this paragraph 2.3. and the various subparagraphs hereof. F. Proof of Coverage and Premium Payments. Within 30 days after each due date thereof, each Party shall furnish the other Party with proof of his/her payment of all policy premiums and of all accrued interest on policy loans. On an 8lU1Ual asis each Party shall furnish b the other Party with proof of the continued existence of the requisite insurance coverage and beneficiary designation. G. Satisfaction of Claims. The Parties' compliance with the terms of this paragraph 2.3. shall be deemed a full and complete satisfaction of any and all claims against each Party's estate for the support for the three children of the parties, such that each Party's estate shall be released from any and all further claims for support or education of the children. 2.4. Children's Educational Expenses. The Parties hereby agree that the tuition for the Children's primary and secondary parochial education shall be shared by both Parties equally. Both parties' obligation shall be offset by any contribution from family for primary and secondary parochial education including "Loans" prior to any contribution from the parties. Each party shall have an affirmative obligation to disclose to the other parent any contribution from their families. For the purpose of insuring that said tuition payments are made in a timely fashion, both parties shall establish automatic transfers from their respective personal checking accounts of their 50% share of the children's parochial school tuition, and said transfers shall occur by the 15th of each month, 12 months per year. If either party fails to make their monthly payments, they shall be solely responsible for all attorneys fees incurred to enforce, this PI~~graI;1h. ~ 5h~(1 J,..etl 5hct~ ~ 'S*. I
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A. Primary and Secondary Education

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B. Post-Secondary Education

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1. Husband and Wife shall pay for a college, university or vocational school education for the parties' children pursuant to section 513 of the Illinois Marriage and Dissolution of Marriage Act, (750 ILCS 5/513) or any succeeding statutory provision, subject to the terms and conditions set forth in this Article. 2. Trusts for the children's post secondary education have been established by the great grandparents of the children. Each party shall have access to Trust documents and records related to the children's post-secondary education. 3. The obligation of the parties shall be reduced by the availability of funds for the children's college expenses, including but not limited to the above mentioned trusts,

Parenting Agreement: Final
9

scholarships, grant-in-aid, fellowships, or other monies designated for the children's education; and the parties shall have no obligation to pay any child's college expenses as set forth in this Article until all such scholarships, grants-in-aid, fellowships, trust funds or other monies designated for that child's educational expenses have been exhausted. 4. For the purposes of this Article, the expense of college, university or vocational school education shall include charges for tuition, room and board, books, fees, tutors, fraternity dues, allowances and transportation expenses between the school and the child's home not to exceed four (4) round-trips per school year if the child is in attendance at an out-of town school. C. Joint Decisions. All decisions affecting a child's education, including the choice of college, university, or vocational school, shall be made jointly by the parties and shall consider the expressed preferences of the child. Neither party shall unreasonably withhold approval of the child's expressed preferences. In the event the parties are unable to agree on any issue related to a child's education, that issue shall be submitted to mediation in accordance with the provisions of subparagraph 1.3.C. of this Agreement. D. Conditions Precedent. The partiesobligations as to each child, as set forth in this paragraph 2.4., are expressly conditioned on fulfillment of each of the following conditions precedent: 1. That the child has the desire and scholastic aptitude for a college, university, or vocational school education at the time in question; and 2. That the child's enrollment is limited to 4 academic years conunencing upon graduation from high school, except that the time of corrunencement and/or the duration of fulltime or part-time enrollment may be extended in the event enrollment is precluded or limited by serious illness or for other good cause. 2.S Uniform Gift to Minors Accounts Certain stock accounts have been established for the minor children by the minor children's great grandparents. Each child has a Uniform Gift to Minor Account at Morgan Stanley. Wife as custodian for these separate account for the children shall provide statements to Husband on an annual basis. All dividends and interest generated by said accounts shall be reinvested. Both parties must agree in writing before the accounts can be invaded, distributed, or moved. Said stock account proceeds shall be distributed to the minor children upon the earlier of (1) a date chosen by mutual agreement of the parties, or (2) upon the minor children's graduation from college or trade school. 2.6. Dependency Exemptions.

Agreement: Final

For purposes of federal and state income taxation: A. Sale Entitlement. The Wife shall be solely entitled to claim the dependency exemption for Megan and Patrick Charles commencing in 2003 and continuing in all future years and the Husband shall be solely entitled to claim the dependency exemption for Joseph. In the event that

Fatheris no longerentit1e:~_li~~::;:'jj'~iffJ;('phall

havethe right to claimMegan.

B. Conditional EntitIeme-riMhe H~d snall be solely entitled to claim the dependency exemption for Joseph' commencing in 2003 and continuing in all future years, provided that in the event the Husband is effectively denied all economic benefit of claiming the exemption for a given calendar year by virtue of federal income tax law, then the right to claim the exemption shall revert to the Wife for that year. The Husband shall have the affirmative obligation to advise. the Wife in writing on or before April 1 of each year, commenting in 2004, as to whether he is able to derive economic benefit from claiming the dependency exemption for J osephj\ Laura shallhavethe sole right to claim head of householdstatuson her tax returns. \~Oc W~""'" IN WITNESS WHEREOF, LAURA and JOE have hereunto set their resp;c.fiv~ hands and seals 0 this Agreement, on the day and year first written above.

=-&J

.

EM'fERE'
MAR 2, 9 1UO~

GRt\CE DlCKLER ~1
COLADA1~Cl AND COLADARCI

JUDGE

#37619

155

NORTH

MICHIGAN

AVENUE, SUITE

• ATTORNEYS FOR PETITIONER 636 -CHICAGO, ILLJNOIS60601 •

TEL.

312-616-4272

FAX

312-861-1874

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4405 Pre-Tria! Assignment,

4406 Status Report,

aringrTrial

Assignment, 4295 Close Discovery-Allos"

\

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION
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IN RE THE EJ- l'vlARRlAGE SUPPORT OF:

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PETITIO~ffiR

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Calendar:
-------------~

AND
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RESPONDENT ORDE.RS OF CONTINUANCE THIS CAUSE being properly before the Court on motion of and the Court being advised in the premises: 0 Petitioner

o Respondent

E, Agreement of Counsel,

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IT IS ORDERED that this cause is set for:

4405

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PRE-TRIAL CONFERENCE

on

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.m. before this Court.

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on

All parties shall be present.

HEARINGITRIAL --------

regarding , at __ ~_~_

-_--.m. before this Court.

~__:___-~

4482

4250

o

All parties to appear in Courtroom Discovery is closed as of

on the stated date and time. _

o

4295

NOTE: CASES SET FOR TRIAL CAN ONLY BE CONTINUED FOR CAUSE ON MOTION PURSUANT TO SUPREME COURT RULE AND DOMESTIC RELATIONS GENERAL ORDER 86-D-1.

Atty. No.: Name: Atty. for: Address:

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ENTERED: /
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Judge COURT OF COOK COUNTY,

DOROTHY BROYVN. CLERK OF THT CIRCUIT

.-. IN THE CIRCUIT COURT OF COOK COUNTY DOl\1ESTIC RELATIONS DIVISION

s:

.

COOK COUNTY, ILLINOIS
IN RE: The Marriage of )

J

LAURA WALSH Petitioner

) ) )

v.
WU..LIAM WALSH
Respondent.

) )
)

NO.~ll~S4

OrSLb(22v

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I

PAGE 1 OF)

AGREED ORDER, This matter coming to be heard by agreement of the parties, for the payment of arresrages and modification of child support, this court being fully advised in the premises, and the parties
having agreed and stipulated to the

following;

Findings:

1.

This order is based on JOE W ALSH)s representation that his total gross income for 2005 is $97,515: ($50)000 from Advantage Futures, $27,000 from Velvet Steam Roller employmentcommencing August 15, 2005, and $20,515 in consulting income from Velvet Steamroller in February and June), and that the support order presently in place is based on his income from Advantage FUMes, only,

IT IS HEREBY AGREED and ORDERED:
A.
As and for additional child support relating to $20,515

in additional gross income

received by JOE WALSH in February and June 2005, JOE shall pay LAURA $4,136 as 28% of the net amount, payable on the fallowing terms:
$1,000 by November 1,2005, $1 ;027 on or before December 15,2005 and the balance in 4 remaining payments of $5.27.2.5, paid by the 15m of each month: January 2006, February 2006, March 2006 and April 2006.

B.

Joe Walsh's monthly child support is modified, as of August 15,2005 on a temporary basis as follows: . Based on gross monthly compensation 0[$10,166,66, his net monthly income is $7,319~ and his 28% guideline monthly child support is $2,049, ill addition, JOE is to pay $85 per month as his contribution to health insurance costs for the children; therefore. his monthly child support is $2,134.

11
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IN THE CIRCUIT COURT OF COOK COUNTY DOMESTIC COOK COUNTY, ILLINOIS ) ) RELATIONS DIVISION

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IN RE:

The Marriage of

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LAURA WALSH
Petitioner

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v.
WILLIAM WAlSH
Respondent.

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NO. 99 D2284

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'I PAGE20f3

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i.

There is presently an order of withholding in place with Advantage Futures, for an amount 0[$1,135, JOE shall make up the difference ($1,000 per month) in two monthly payments of$500 each to LAURA, directly, payable on the 151.\1nd the 301'Hof each month commencing a November 15, 2005, and continuing on the 15 and 30<'0. each month of thereafter unless otherwise modified. It is understood by the parties that JOE's additional income, commencing August 15, 2005; maybe temporary, and they agree and stipulate that said increase in child support is to be reviewed in December; 2005, to determine if the additional income from Velvet Steamroller is on-going.

C.

Additional child support payments for August, September, and October, 2005: "1 ~A"TTn" t ,. ,." Joe sna; paY.LA ~u KP~the a..'11.0UJl. rfq:"~on.U trnrne diiarery, as aclditi o _L.,) rnonai , cnuo support pursuant to paragraph B, above.
T

D.

The parties agree that JOE shall provide to LAURA~ within 7 days of the filing thereof, his 2005 tax returns and all attachments, including 1099 and W2 forms. and that: i. any underpayment by JOE of guideline child support calculated pursuant to this order, based either on additional 2005 income not herein disclosed, or on an adjustment of child support based on actual tax paid, shall be reimbursed to LAURA as additional child support within 14 days of the filing of his 2005 tax returns.

ii. Any overpayment of child support by Joe due to a recalculation of
deductions for actual tax. paid shall be reimbursed to JOE within 14 days of the filing of his 2005 tax returns, provided that he is current with his child SUDDort oblizations.
....... L...'.

IN THE CIRCUIT COURT OF COOK COUNTY DOMESTIC RELATIONS DIVlSION COOK COUNTY, ILLL'lOIS·
IN

RE:

The Marriage of

) )

LAURA WALSH Petitioner v. WILLIAM WALSH Respondent.

) ) )

NO. 99 D 2284

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PAGE 3 OF3

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STATUS on child support is set for December

_,==,JL..:ILL(2~_ _" 2005.

This Order is Nunc pro tunc to November 1, 2005.

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LAD'RA . WALSHJ /)
ENTER:

Attorney Code: 37619 Law Offices of COLADARCI & COLADARCI 155 N. Michigan Avenue, Suite 636

Chicago, Illinois 60601312-616-4272

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(Rev. 117/03) CCDR 0556 A IN THE CIRCUIT COURT OF COOK COUNfY, ILLINOIS COUNTY DEPARTMENT - DOMESTIC RELATIONS DIVISION

NOTICE TO WITHHOLD INCOME FOR SUPPORT

LAURA J. WALSH
And Petitioner

Case No. 02 D 230912 TO: PAYOR/E~LOYER Name! Company Respondent Address 30 City Chicago State

WILLIAM J. WALSH

Advantage Futures, LLC Suite 2020
County -=C:.;::o..;;:.o~k Zip ...;.6-=--06;;..,;;0c.;:.6

S. Wacker,

_ _ _

IL
312

Telephone (

) ...::..3..;;..82_-_19:......:0,.;;;.0

Employee/Obligor's Name (Last, First, Middle) William]. Walsh Date of Birth 12/26/61

---------------------

Social Security No. _3_3_4-_4_2_-6_2_5_6

------~---------------~------------~-------_
State .;..IL_______________ Zip 60201

Residential Address 1415 City Evanston

Sherman, #406 ----------~----------------------------------------------------County C.=....:;.oo;;;.;k:..::.._ ---'" Work Telephone ( _

Mailing Address (if different) Home Telephone ( )

Driver's License No. (Illinois) Employee Identification No.

--------------- Driver's

)-----------------License No. (other state) -------------------

----------------J. Walsh ----~----------------~----------------_

Custodial Parent's /Obligee's Name (Last, First, Middle) Laura Date of Birth 4/12/65

~~~--------------Social Security No. ...;;4'-'-7..;:..8-....:;9....::.6__;-6;.,..;;7..;;;3....:...7
W. Harrison, Apt. 1
State _IL Zip 60201 ___;_ Work Telephone ( 847 _ County .c.::.C_0.;:c0k

Residential Address 2110 City Evanston

Mailing Address (if different) Home Telephone (

847

) ....:.9_5.:::..1--'-0'-2_4-"-3

) _9o_5_-_32_4_3

--,--

_

Driver's License No. (Illinois)

------------~----Driver's

License No. (other state)

-----------------4)

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK

(Rev. 117103) CCDR 0556 B Child(ren) covered by Order For Support: Name(s) (Last, First, Middle) Sex Date of Birth Social Security No.

Walsh, Megan R. Walsh, Patrick C

F M

12/5/90
9120/94

NOTICE INFORMATION: This is a Notice to Withhold Income For Support based upon the attached Order for Support, entered by the Honorable Judge Grace Dickler , Circuit Court of Cook County, Illinois on

. By law, you are required to deduct the following amounts from the above-named employee'sfobligor's income until _Tune 30 , 2013 even if this Notice to Withhold Income for
Support is not used by your State.

Aoril13

,2005

s
$ $ $

1,135.75

per month

===-

in current support; in past-due support until $

per ________ per _-'per _______ per _______

is paid in full;
[J yes [J no

Arrears 12 weeks or greater?
in medical support; .in other (specify):

s
Total $

in other (specify):

-,-_

1,135.75

per ""--=::.__----- withheld to be paid over and sent to: month

STATE DISBURSEMENT UNIT; P.O. BOX 5400; CAROL STREAM, IL 60197-5400 for payment to the obligee. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold:
$ $

262.10 524.19

per weekly pay period. $ .::;5_:,6.::.7_.8_8 per biweekly pay period.
$

per semimonthly pay period (twice a month). per monthly pay period.

1,135.75

If checked, you are also required to immediately enroll the child(ren) identified above in any health insurance coverage available through the employee/obligor's employment, and withhold or cause to be withheld, if applicable, any required premiums. Premiums withheld shall be made to the health insurance plan in a timely manner. You are required to mail to the obligee, within 15 days of enrollment or upon request, notice of the date of coverage, specific information regarding the dependent benefits/coverage plan, and all forms necessary to obtain reimbursement for covered health expenses, such as would be made available to a new employee. When an order for dependent coverage is in effect and the insurance coverage is terminated or changed for any reason, you must notify the obligee within 10 days of the termination or change date along with notice of conversion privileges. REMITTANce INFORMATION: Follow the laws and procedures of the State of the employee obligor's principal place of employment even (f such laws and procedures are different from this paragraph: You must begin withholding no later than the first pay period occurring 14 days after the date of this notice. You must send the amount withheld to the STATE DISBURSEMENT UNIT; P.O. BOX 5400; CAROL STREAM, IL 60197-5400 within 7 business days of the pay date. You are entitled to deduct afee of your actual cost not to exceed $5.00 per month from the income to be paid to the obligor in order to defray the cost of withholding. The total amount withheld, including your fee, cannot exceed the amount permitted under the Federal Consumer Credit Protection Act
(page 2 of 4)

o

(Rev. 1/7/03) CCDR 0556 C When remitting payment, provide the pay date that you withheld support; state that the order for support was entered in the Circuit Court of Cook County; Case No.02 D 230912 . your name, address (including county), and telephone number; the obligor's name, address (including county), social security number; and driver's license number and the obligee's name, address (including county), social security number and driver's license number. Coladarci and Coladarci Name ~ Attorney of Record ADDITIONAL INFORMATION
[J If checked,

Cl Obligee

Date of Notice AND OBLIGORS

TO EMPLOYERS/PAYORS

you are required to provide a copy of this NOTICE to your employee.

TO THE PAYORIEMPLOYER= 1. PRIORITY: Withholding under this NOTICE has priority over any other legal process under State Law against the same income. Federal tax levies in effect before receipt of this NOTICE have priority. If there are Federal tax levies in effect, please contact the requesting attorney or obligee listed below. 2. COMBINING PAYMENTS: You can combine withheld amounts from more than one employee/obligor's income in a single payment when sending payment to the State Disbursement Unit. You must, however, separately identify the portion of the single payment that is attributable to each employee/o bligor and include his/her social security number and driver's license number. 3. REPORTING THE PAY DATEIDATE OF WITHHOLDING: You must report the pay date/date of withholding when sending the payment. The pay date/date of withholding is the date on which the employee is paid and controls the income, Le, the date the income check or cash is given to the employee, or date on which the income is deposited directly in his/her account. 4. EMPLOYEE/OBLIGOR WITH MULTIPLE SUPPORT WITHHOLDlNGS: If you receive more than one NOTICE against this employee/obligor and you are unable to honor them all in full because together they exceed the withholding limit of the State of the employee's principal place of employment you must allocate the withholding based on the law of the State of the employee's principal place of employment. If you are unsure of the State's allocation law, you must honor all NOTICE of current support withholding before you withhold for any arrearages, to the greatest extent possible under the withholding limit. 5. TERMINATION NOTIFICATION: You must promptly notify the obligee, and the Clerk of the Circuit Court when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this NOTICE to the obligee, and the Clerk of the Circuit Court. EMPLOYEE'S/OBLIGOR'S EMPLOYEE'S/OBLIGOR'S EMPLOYEE'S/OBLIGOR'S EMPLOYEE'S NEW EMPLOYER'S NAME: WilliamJ. Walsh CASE NUMBER:

~~~~~~~--------------------------------------------.=..0=-2 =D_:2::..::3c..::;.0.::..91::..=2=---_ ~ __ .,.._------C- __

LAST DATE OF EMPLOYMENT:

_ ------'_

LAST KNOWN HOME ADDRESS: ADDRESS:

6. LIABILITY: If you fail to withhold income as the NOTICE directs, you are liable for both the accumulated amount you should have withheld from the employee's/obligor's income and any other penalties set by State law. You may be found liable for the total amount which you fail to withhold or pay over and fines up to $100.00 per day for each day after the 7 day grace period. See Illinois Statutes 305 ILCS 5/10-16.2, 750 lLCS 5/706.1, 750 ILCS 15/4.1 or 750 ILCS 45/20,750 ILCS 5/507. 7. ANTI-DISCRIMINATION: You are subject to a fine determined under State law for discharging an employee/ obligor from employment, refusing to employ, or taking disciplinary action against any employee/o bligor because of child support withholding. 8. WITHHOLDING LIMITS: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CePA) (15 U.S.C. sec. 1673(b»; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions, including but not limited to: State, Federal, local taxes; Social Security taxes; and Medicare taxes. The Federal CCPA limit is 50% of the ADWE for child support and alimony, which is increased by: 1) 10% if the employee does not support a second family; and/or 2) 5% if arrears are more than 12 weeks old (see appropriate box on front).
(page 3 of4)

(Rev. 1/7/03) CCDR 0556 D

TO THE OBLIGOR: 1. CONTESTING WITHHOLDING: An Obligor may contest withholding commenced by this NOTICE only by filing a petition to contest withholding with the Clerk of the Circuit Court within 20 days after service of a copy of the income withholding notice on the obligor. The grounds for the petition shall be limited. See illinois Statutes 305 ILCS 5/10-16.2 and 750 ILCS 5/706.1. 2. MODIFY, SUSPEND, TERMINATE OR CORRECT WITHHOLDING: An obligor may petition the court, at auy time, to modify, suspend, terminate or correct a withholding notice. See illinois Statutes 305 ILCS 5/10-16.2 and 750 ILCS 51706.1. 3. CHANGE OF ADDRESS: The obligor must notify the obligee, the public office, and the Clerk of the Circuit Court of any changes of address within 7 days. 4. CHANGE OF EMPLOYER: The obligor whose income is being withheld, or who has been served with a notice of delinquency, must notify the obligee, the public office and the Clerk of the Circuit Court of any new employer, within 7 days. 5. ANTI-DISCRIMINATION: An Obligor may not be discharged, disciplined, denied employment or otherwise penalized by a Payor because of the Payor's duty to withhold income. 6. ADDITIONAL RIGHTS, REMEDIES AND DUTIES: For the obligor's additional rights, remedies and duties, ifthe principal place of employment is illinois, see Illinois Statutes 305 ILCS 5/10-16.2,750 n,CS 5/706.1, 750 ILCS 15/4.1 and 750 n,CS 45/20.

Requesting Attorney: Address: 155 N. Michigan Ave., Suite 636 City/State/Zip:

_

Obligee's Signature: Obligee's Address: City/State/Zip: Phone: Fax: ---..,.-_--

----_ _

Chicago, IL 60601

Phone: (312) 616-4272 Fax: (312) 861-1874 Atty. No.~37~6~1_9

---------------------__

_

(Page 4 of 4)

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

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This is Google'scacl\e of http://walshforcongress.com(ahoutl_ It is a snapshotof the pageas it appearedon Dec 3, 2010 23:33:24 GMT, The currem pagecould have changedin the
meantime. learn more

-----------------._---

----------------,

ABOUT ISSUES ENDORSEMENTS NEWS

Press Releases Video Gallery Photos
EVENTS lOIN US

Voter Information
DONATE CONTACT

Republican Candidate for United States Congress from Illinois Eighth District
Joe was born and raised In the heart of the Eighth District, growing up in a family of nine children, He has been a lifelong advocate for limited government and a vibrant private sector, Now, troubled by the recent rapid growth of government spending and involvement in our lives, he's retuming to his roots and running for the u.s. cOngress, He Intends tD be a loud, forceful voice against this expanding government which wi!! stifle economic growth and bankrupt our children and grandchildren, Joe Walsh has been a hardworking American from the jump - and he's dedicated his professional life to service. He has advocated on behalf of a wide range of public policy issues and causes, most notably advancing market-based solutions to education reform and urban poverty. Rather than spending time in an Ivory tower speculating on theory, he has had his boots on the ground for a number of relevant companies, causes and dlsclpllnes. • • • in inner-city Chicago, he worked With Jobs for Youth, teaching basic academic skills to high school dropouts and job

IEmail
---VOLU NTEER

Recent News
2634 ".;ling Address Media: Bean Hides From Voters, Blames The Voters

Incumbent Melissa Bean continues to hi~ei where Is the media outrage? Early Voting Information

Latest Twitter
This morning we took the Freshman class picture ... Can you see me?~ http://plixi.com/p/S7871137 2010/11/19 At the House office lottery] Good news is that almost all the worst numbers heve been drawn. ExClted to see what number I get! 20W/l1/19 Let"s do It agatn! Please join us fora proper victory celebration on Sunday 4: 00 - 5:00 PM @ Lakemoor Banquets, Cash bar &. appetizers. 20W/H/18 Victory:

he advanced the issue of school choice while working for The Heartland Institute, a Midwest free market think tank he was the Executive DIrector of the Daniel Murphy Scholarship Fund overseeing an annual budget of $2M. The fund is a Chicago-based privately funded school voucher program which gives high school scholarships to lew-income students he helped launch the ~egislative Education Action Drive and Americans for limited Government organizations, national organizations working to get fiscally conservative state legislators elected in targeted states and advance the causes of limited. government he raised funds for two of the nation's leading school choice organization, the

http://tinyurl.com/32srxpS
2010/11/17

• •

American Education Reform Council and the Milton & Rose Friedman Foundation he continues to ratsa funds and build support for the Fabretto Children's Foundation, an international charity which uses education and micro-enterprise to deliver Nicaraguan children from poverty raising nearly $lM the past five years: the For the past couple of years, Joe has worked with Ravenswood Advisors, a Chicago-based boutique investment banking group focused on raising early stage investment capital for new and small businesses and entrepreneurs, He consulted With the United Republican

http:!{bit,IV/9AwrWm we have lawyers overseeing the ballot
counting process. thank you to the. #GOP for sending a team as well! 2010/11/11

Walsh

Horse Trailer

Fund, an IllinOis-based state PAC helping to elect Republican state leg;slators.

http://webcache.googleusercontent.comlsearch

?q

10

Joe waisn tor congress I

congreSSIOnal VIsmCI uunois »

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Joe has run spirited campaigns for elected office twice, first as a Republican candidate for the US Congress in 199B. in 1996 and then as a Republican candidate for the Illinois Statehouse

Joe has a BA in English from the University of Iowa and a Masters in Public Policy from the University of Chicago. He has taught American government and American history at the community college level for a number of years. He and his wife Helene have five children. Paid for and Authorized by the Joe Walsh for Congress Committee, 21B foIorthBarron Blvd (Rt. B3) , Grayslake, IL 60030

© 2010 All Rights Reserved I Powered by Political Technology

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FEe FORM 3
REPORT OF RECEIPTS AND DISBURSEMENTS
For An Authorized Committee FILING FEC-509588

1. JOE WALSH FOR CONGRESS COMMITTEE,
P.O. BOX 56 830 W. ROUTE 22 LAKE ZURICH, Illinois 60047 State is Illinois in District: 8 2. FEC Committee ID #: C00473579 3. This report IS au AMENDMENT 4. Report Type = PRE-GENERAL For election on 11/0212010 in the StateofTIlinois Filed 10/2112010

INC.

SUMMARY PAGE DETAILED SUMMARY PAGE Schedule A Filings aTEMIZED RECEIPTS) Schedule B Filings aTEMIZED DISBURSEMENTS) Schedule C Filings (LOAN INFORMATION) Schedule D Filings (DEBTS AND OBLIGATIONS) (End FEC FORM 3)

SUMMARY PAGE

Of Receipts And Disbursements.
5. Covering Period 1010112010 Through 10/13/2010

.... (a) ~t.(lI~ol1t:ibll!i:~Il:s. (oQ1~rt11~}93:Il:~J== = ~":=-=2=0=8=9~. =_=_=4_3~(j9=4=}=. _.= 9 O=)O=;..' 0=96' (b) Total Contribution Refunds 0.00 1087.86

I

17. Net Operating
.~ 00000 .~ __ ."."n ~'" _ 0.,\::::::;;""""""""

".-;-m

Expenditures
""
T ~'''T _ _ .•.
L.........

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""•••T.TTT

~"_O~_"

_•••

H_TT.TTT··

(a) Total Operating Expenditures ._______ ._._ .... i8. Cash on Hand at Close of Reporting Period 1'9. elJt~ and Ob1igation~ Owed TO th~ C~~ittee D Itemize all on SCHEDULE C or SCHEDULE D 10. Debts and Obligations Owed BY the Committ Itemize allan- - SCHEDULE C or SCHEDULE D
.. .... _ ...

21539.92! 0.00 21539.9: 4089.1' 0.00 84027.98

460486.89 1.67 460485.22

l (~2~ et 0l?_~,(l!i:Il:~~~E~Il:c}it:ures

Treasurer: Helene M~ .Miller-Walsh Date Signed: 10/21/2010

(End Summary Page, FEe FORM 3)

DETAILED SUMMARY PAGE
Of Receipts And Disbursements

I
I. RECEIPTS Ill. Contributions (other than loans) From: (a) IndividualslPersons
~

ColumnB El ti Column C jl~~isperio~lC:;Ycle~~o~~~te Post-Election

I ! h-.ColumnA 1

Other than Political Committees

I

..

(ii) Unitemized (iii) TotalOf Contributions From Individuals .(b) Political Party Commitees --_,_......

15304.00 j:=~5~59=5=.0=0r==~===~~~==! 20899.00!

)

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.. ,_

•.........

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0.001 O.OO~

._.0.091
8099.00\

(d) The Candidate

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O.OO!
no'1

--.. ~I

(e) Total Contributions (l}_((l)(iii) +- (lJ)_+- (c))

O.OO! 1

i

12. Transfers From Other Authorized Committees
,,,.,, ,,_,._0... , __ "

",._·c._.e

•• __ •••••

~

0.00
••

7419.19 35500.00 35500.00 1.67

0.00 0.00 0.00 0.00 0.00 0;00

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13. Loans _(a.)"tv1a.d~.<?r_ g~ar~te~~By (c) TotalLoans ((a) + (b)) :14. Offsets to Operating Expenditures (Refunds, Rebates,etc) The Candidate
_II

0.00' 0.00 .... 0.00

0.00 16. Total Receipts (11(e) + 12 + l~(c~ + 1~ + 15) 'I 20899.00 _479863.92 II. DISBURSEMENTS 17:Opera.tit:g E)(pendit~es::-: -:-.~ --.. _"'y---.... ••.... . . -_JI~. ~ .. ~=15=3=9=.~=_?"~==4~6~~~48~6~ = ..~.8~~2"F""'_.-_ ...... ~~O.~O~O = . _~_ l~.!,ran~fers to Other Authorized Committees
!

'I

0.00 240 . 0.0( 2400.0(

0.00

0.00

12_~!:?a.l?:_~~pa~~l1ts: ___ _ __ "ja.) Of !:'?~~_~~_?r._ Guar~tee..d by the ~andidate_ (b) Of All Other Loans __ (C?)__1.'0tal L0all.Repaytllents ((a)~ (b)) 20. Refunds of Contributions To:
•• • ." .. _.'. _ ~, ..•••. , ••• ,._.. c_ •••• _...... _.".. • " ••••• ~ •••. ,~., ... ,._.,, __ ••• __ .".,_

0.00 14200.00 \

0.00

_T_

•• ~ ...__

___ Individuals/Persons Other Than Political Committees (a.)
!.

<?) Other P()li,ti~a.l 0Il1?1:~~tees C (such as PAC~ 2. . (d) Total Con~bution Refunds (28(a) +(b)~J?) 21. Other Disbursements
(

_(1)) Politica.I ~~y_C_ommittees

0.00

g.og!

1087.86 0.00 475774.75g.09

0.00 0.00

23939:221__ III. CASH SUMMARY

i_M_._T_o_W~R_~_ed~=~=T=h=~=P=e_ri_~~Om_:_e_J~0~~~~~~~~ J=~_~_~_~Oi(4~8~·~1_ '25. Subtotal (~3+ 24) 28029.' --

0.00

:_26~.~T~0~ta~1_D~i~sb~ur~s~~_ce~ri_()~d._,...,9=~,~=ce~2=2';")~~~~_==tl=~2~39_3_9~. ... ce_rn~e.n_t_s=!~.!ll_·s_ ... -=-\,"'._...=__ ........ 4=.7~_5~7~?4~.: ~~~_O.~O~O :27. Cash On Hand At Close Of The Reporting Period (25 - 26)i 4089.171

--~~~~~~--------------------------~r-----(End Detailed Summary Page, FECFORM 3)

-------~

Generated Tue Nov 23 18:07:372010

SCHEDULEB
ITEMIZED DISBURSEMENTS . All Listed Line Numbers

Committee: JOE WALSH FOR CONGRESS COMMITTEE, INC.

llr=Am=·=e=n=. c=an=E=x=p=re=s=~-=..______ ,___

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Generated Tue Nov 23 18:12:252010

Schedule C for ALL Line

Page 1 of4

SCHEDULEC
LOAN INFORMATION All Listed Line Numbers Committee: JOE WALSH FOR CONGRESS COMMITTEE, INC. Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave. McHemy, Illinois 60051 . Description: Date incurred = 12/04/2009 . Date due = 12/05/2014 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #:10 Original Amount of Loan = 4500.00 Amount Paid To Date = 4500.00 Loan Balance = 0.00

Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave. McHenry, Illinois 60051 Description:

httn:llauerv.nictusa.com/cgi-binJdcdev/fonns/C00473579/509588/scl

ALL

11123/2010

Schedule C for ALL Line

t(

Page 2 of4

Date incurred = 01119/2010 Date due = 01/20/2015 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #: 10

Original Amount of Loan = 2000.00 Amount Paid To Date = 700.00 Loan Balance = 1300.00

Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave. McHenry, Illinois 60051 Description: . Date incurred = 01/23/2010 Date due = 1124/2015 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #:10

Original Amount of Loan = 8000.00 Amount Paid To Date = 0.00 Loan Balance = 8000.00

Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave. McHenry, Illinois 60051 Description: Date incurred = 01126/2010 Date due = 01127/2015 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #:10

Original Amount of Loan = 4000.00 Amount Paid To Date = 0.00

http://query:nictusa.comlcgi-binldcdev/forms/C00473579/509588/sc/ALL

11123/2010

Schedule C for ALL Line Loan Balance
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Page 3 of4

4000.00

Loan Source: Joe Walsh .. [PERSONAL FUNDS]
221 0 Woodlawn Park Ave. McHenry, Illinois 60051 Description: Date incurred = 02/02/2010 Date due = 02/03/2015 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #: 10 Original Amount of Loan = 1000.00 Amount Paid To Date = 0.00 Loan Balance = 1000.00

.Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave, McHenry, Illinois 60051 Description: Date incurred = 06/26/2010 Date due = 612712015 Interest Rate == 0.0000 This Loan Is NOT Secured Included In Summary Line #: 10 Original Amount of Loan = 5000.00 Amount Paid To Date = 0.00 Loan Balance = 5000.00

Loan Source: Joe Walsh - [PERSONAL FUNDS]
2210 Woodlawn Park Ave. McHenry, Illinois 60051

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1112312010

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Page 4 of4

Description: Date incurred = 08/11/2010 Date due = 08/12/2015 Interest Rate = 0.0000 This Loan Is NOT Secured Included In Summary Line #:10 Original Amount of Loan = 2000.00 Amount Paid To Date = 0.00 Loan Balance = 2000.00

Total Loans This Period
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21300.00

Generated Tue Nov 23 18:05:55 2010

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Fox Chicago Sunday: Joe Walsh
Updated: Friday, 02 Apr 2010, 4:53 PM COT Published: Friday, 02 Apr 2010, 4:53 PM COT FOX Chicago News Chicago - Eighth district congresswoman Melissa Bean said she believes her vote for health care reform, reflects the feelings of her constituents. The republican running against Bean in November's general .election said a new poll suggests otherwise.

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Joe Walsh is a businessman and a father of five, who lives in Winnetka and he joins us this morning on Fox Chicago Sunday.

http://www.myfoxchicago.comldpp/wildcard_8/foxchicagosunday/201004...11/23/20

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GOP Congressional Candidate Joe Walsh Fails To File Personal Financial Disclosure Form
Updated: Tuesday, 27 Apr 2010,11 :07 AM CDT Published: Monday, 26 Apr 2010,8:51 PM COT By Jeff Goldblatt, FOX Chicago News

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Chicago - Joe Walsh ran <;IS an outsider against five candidates to win February's Republican primary in Illinois' 8th Congressional district. ' "I'm a bit of a rogue.

I'm a bit of a loose cannon," Walsh said during a sit-down interview with Fox Chicago.

But he's not a political rookie by a long shot. In 1998, he made a run for the Illinois House as the Republican nominee of what was then the 58th District. Additionally, in 1996, he represented the GOP as its nominee in the 9th District against the late-Rep. Sidney Yates, one of Congress' longest serving members. Given Walsh's experience with political campaigns, you might think he should know what paperwork he's legally obligated to file as a candidate, but a FOX Chicago News investigation discovered Walsh failed to file his personal financial disclosure form as required by federal election law. FOX Chicago News sent a producer to. Capitol Hill to check the computer database that keeps track of the personal financial disclosure records of Congressional candidates and sitting members. We noticed all of Walsh's opponents had filed this paperwork, but his was conspicuously absent, as we showed him during our interview. "I'm not doubting the accuracy of that," Walsh said after looking at a picture of the Congressional database which showed the candidates who had filed this form, and the fact that Walsh's paperwork was rnisslnq, When asked if he was trying to hide something, Walsh said, "Oh God no. On God no. Not at all." Chicago election-law attorney Burt Odelson, one of the nation's premier experts in helping political candidates get their paperwork in order, says it's a serious violation that Walsh failed to file this form. "It's the document that creates a transparency as to the Congressman or the nominee's holdings to let the public know who he is, what he has, and do you want to vote for him, if he's voting on things in Congress that he has a conflict with," Odelson said. "It's a big deal. And the reason we know it's a big deal is because of the penalties in the Congressional Act that says if you don't do this, the Attorney General can bring suit against you, that you can get up to $50,000 in civil fines." When politicians declare their candidacy, they automatically get a personal financial disclosure form in the mail. Under federal election law, candidates are told they must file the form no later than 30 days before an election. Questions about Walsh's finances have recently dogged his campaign. After the primary, news surfaced that Walsh lost his Evanston condominium to foreclosure last June, because he owed more than $300,000 on the property. Walsh says he's a venture capitalist who averaged $40,000 in income the last two years but then fell on tough financial times. However, he still managed to scrape together enough money to rent a $3,300 per month house in. upscale Winnetka.

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11/23/2010

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"It was my own mistake. This whole foreclosure thing. I could hit myself. I should have talked about it in the primary. I wasn't hiding it, because it was a public record," said Walsh. And now the public record shows Walsh loaned his campaign $28,500 just a half year after the foreclosure of his condo. Walsh listed the loan on his latest campaign finance disclosure form, filed With the Federal Election Commission. Walsh characterized it as a "terribly risky" loan. "That's literally every cent we had, combined with a little extra I brought in that month to he said. "Some people might say that's reckless, but so what?"

try and win the primary,"
.

Walsh says it was too late to save his condo when he loaned the money to his campaign. But is it too late to save his own political skin? Joe Folisi is on the Executive Committee of Schaumburg Township Republicans. Mark Cramer is one of the group's precinct captains. In the primary; that organization supported two candidates, but not Walsh. In light of the revelations in this story, both men have called on Walsh to get out of the race. "It's a seriousthlnq to have someone who's won his party's nomination to ask him to step down, is a big deal. It's serious business. And we take it seriously," said Cramer. "This goes to the integrity and honesty of the candidate," said Folisl. "I mean you have certain requirements and rules you have to follow and if you can't follow those rules, then, I think you need to give serious consideration to somebody else taking the reigns who will follow the rules. Both men say their declsion to step forward is not a case of sour grapes, that instead they view this as a chance to put up a stronger Republican against three-term incumbent Rep. Melissa Bean. . "I want to put our best candidates forward. And I feel badly (Walsh) didn't come forward before the primary with some of these issues, so that the public would have had an opportunity to make a decision," said FolisL Walsh says he's not going anywhere, "I won a six person primary by1 0 percentage points. We're running a great general election. Not only am I not going to step down, I'm going to win this race," Walsh said. The Walsh campaign insists support has never been stronger, and argues that's why they're faclnq this new criticism. "You have a small group of people with ulterior motives spreading misinformation and attempting to enlist whoever will listen to help them blow marginal issues totally out of proportion," said Walsh Communications Director Whitney Schlosser. Schlosser tells FOX Chicago the campaign plans to file Walsh's personal financial disclosure by the end of the week, along with the required $200 late fee. She says the mistake was due to careless oversight and was not intentional. She placed some blame on the shoulders of former Walsh campaign manager Keith Lisclo, Reached by phone, Liscio denied it was ever his job to oversee this form. "It was, unequivocally, never part of my job. It was the responsibility Walsh's wife," Liscio said. of the Campaign Treasurer, who is Joe

http;//~.myfoxchicago.com/dpp/news/investigative/20

100426-joe-wals... 11123/2010